David Fields v. City of Pittsburgh, 714 F. App'x 137

Background

Fields owned a car dealership next to his wife’s daycare; a vehicle blocking the daycare prompted a police response on July 8, 2013.
Officer Labella told Fields to move his van; an exchange escalated after Labella refused to move his cruiser and called to tow the van.
Fields recorded Labella on his phone; Fields alleges Labella slapped him, knocked the phone away, and grabbed his collar, but Fields later described the contact as brief.
Later, Fields confronted officers near Lieutenant Reilly’s car, made two quick moves toward Labella with fists balled, and was handcuffed after resisting; a Taser was used.
Fields pleaded guilty to reduced state charges (harassment and disorderly conduct). He sued under 42 U.S.C. § 1983 asserting false arrest, Fourth Amendment excessive force, conspiracy, and state tort claims; the District Court granted summary judgment for defendants and declined supplemental jurisdiction over state claims.
On appeal, Fields challenged Heck preclusion of his false-arrest claim and argued the officers used excessive force (challenging both the initial slap and the later Tasing).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Fields’ false-arrest § 1983 claim is barred by Heck v. Humphrey	Fields contends officers lacked probable cause and fabricated an affidavit of probable cause, so his § 1983 false-arrest claim should proceed	Defendants argue Fields’ guilty plea admits probable cause; Heck bars collateral attack on conviction via § 1983	Held: Heck bars the false-arrest claim because Fields’ guilty plea implies probable cause and has not been invalidated
Whether Labella’s initial slap/grab constituted a Fourth Amendment seizure or excessive force	Fields argues the slap was a battery that provoked later force and should be considered in the excessive-force analysis	Defendants argue the slap/grab was brief and did not amount to a seizure; thus it does not trigger Fourth Amendment protection for that act	Held: The slap/grab was not a seizure (Fields moved freely afterward), so it did not violate the Fourth Amendment
Whether officers’ use of a Taser and force in arrest was excessive	Fields argues the earlier provocation and the circumstances made the Tasing unreasonable	Defendants argue probable cause existed (supported by the plea), Fields made threatening gestures and resisted, and the Tasing was proportional and reasonable	Held: Use of the Taser during a valid arrest was objectively reasonable given threatening gestures and active resistance; excessive-force claim fails
Whether the district court should exercise supplemental jurisdiction over state-law claims after dismissing federal claims	Fields implicitly favors keeping state claims in federal court	Defendants supported dismissal of federal claims and decline of supplemental jurisdiction	Held: District Court did not abuse discretion in declining supplemental jurisdiction over state claims after disposing of federal claims

Key Cases Cited

Heck v. Humphrey, 512 U.S. 477 (bars § 1983 claims that would impugn a conviction not invalidated)
Graham v. Connor, 490 U.S. 386 (excessive-force reasonableness factors)
County of Los Angeles v. Mendez, 137 S. Ct. 1539 (separate analysis for each seizure; limits on provocation rule)
Saucier v. Katz, 533 U.S. 194 (qualified immunity and excessive-force analysis)
Wright v. City of Philadelphia, 409 F.3d 595 (probable cause can be for any offense supported by circumstances)
Barna v. City of Perth Amboy, 42 F.3d 809 (probable cause principles)
Groman v. Township of Manalapan, 47 F.3d 628 (false arrest requires absence of probable cause)
Johnson v. City of Philadelphia, 837 F.3d 343 (discusses foreseeability, provocation, and proximate causation in force cases)
Estate of Smith v. Marasco, 318 F.3d 497 (force use in arrests)
Shuman ex rel. Shertzer v. Penn Manor Sch. Dist., 422 F.3d 141 (Fourth Amendment seizure standard)
Brady v. United States, 397 U.S. 742 (guilty pleas not invalid merely to avoid harsher sentence)