Courtney Adams v. Blount Cty., Tenn., 946 F.3d 940

Late-night call reported three suspicious people near Winchester Drive; Deputy Jerry Burns encountered Anthony Edwards and another man; Edwards gave a false name and acted furtive.
Burns patted down Edwards; Edwards fled, was chased, subdued, handcuffed, and later escorted toward a patrol SUV with Deputy James Patty.
Eyewitness accounts conflict and no video captures the critical moments: deputies say Edwards ran and Burns "slammed" him after a struggle/kick; one witness describes tangled feet and a fall; another later asserts Burns hit Edwards.
Edwards was transported to the hospital and autopsy found occipital skull fractures and blunt-force injuries consistent with an "accelerated fall" to the back of the head; manner of death: homicide.
Plaintiffs sued under § 1983 and state law for excessive force and related claims; the district court denied Burns qualified immunity on the Fourth Amendment excessive-force claim amid genuine factual disputes.
On interlocutory appeal the Sixth Circuit dismissed for lack of jurisdiction because the appeal raised disputed facts (not purely legal questions) that the court could not resolve on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Burns used constitutionally excessive (potentially deadly) force	Burns used excessive force causing fatal blunt-head trauma	Force was non-deadly, reasonable, and caused by a fall/escape attempt	Appeal dismissed for lack of jurisdiction because core facts are disputed; district court's denial of qualified immunity stands for now
Whether Edwards posed an immediate/severe threat justifying deadly force	No: handcuffed, unarmed, unlikely to escape; no severe threat	Yes: Edwards fled/kicked an officer, creating a threat	Court could not resolve; factual disputes preclude appellate review
Whether the record contains facts "blatantly contradicted" (Scott v. Harris) so the court may accept a contrary version	Plaintiffs: credibility issues support district court's view	Burns: contends record demonstrates a contrary (his) version	Not blatantly contradicted by record; credibility conflicts remain, so appellate review is barred
Whether Burns framed his appeal as purely legal (conceding Plaintiffs’ facts)	Plaintiffs: Burns disputes key facts and did not concede plaintiffs’ view	Burns: argues denial of qualified immunity raises legal question on clearly-established law	Burns failed to concede the most favorable facts; because disputed facts are crucial, the court lacks jurisdiction

Mitchell v. Forsyth, 472 U.S. 511 (recognizing narrow interlocutory appeal right from denials of qualified immunity)
Harlow v. Fitzgerald, 457 U.S. 800 (establishing the modern qualified immunity standard)
Saucier v. Katz, 533 U.S. 194 (two-step qualified-immunity inquiry regarding constitutional violation and clearly established law)
Scott v. Harris, 550 U.S. 372 (allowing appellate courts to disregard plaintiff’s version when record—in that case video—blatantly contradicts it)
Johnson v. Jones, 515 U.S. 304 (denying interlocutory review of fact-bound denials of qualified immunity)
Phelps v. Coy, 286 F.3d 295 (defendant may concede plaintiff’s facts on appeal to present purely legal questions)
DiLuzio v. Village of Yorkville, 796 F.3d 604 (separating reviewable legal issues from unreviewable fact disputes in qualified-immunity appeals)
Barry v. O'Grady, 895 F.3d 440 (noting narrowness of interlocutory appeal exception for qualified immunity)
Simmonds v. Genesee County, 682 F.3d 438 (de novo review standard for qualified-immunity summary-judgment rulings)