Dextric Williams v. City of Cleveland, Mississippi, 736 F.3d 684

On July 23, 2010, Cleveland police officers Stanley Perry and Bryan Goza pursued and attempted to arrest Jermaine Williams after he fled; Williams had used cocaine earlier that evening.
Officers warned Williams he would be tased if he resisted; he was tased three (possibly four) times and at one point reached for an officer’s Taser and gun; two additional officers ultimately subdued him.
After being handcuffed Williams lapsed into unconsciousness and died; the evaluating physician listed cause of death as toxic effects of cocaine in association with shocks with Taser during police chase.
Dextric Williams (brother of deceased) sued: products liability against Taser International (failure to warn and manufacturing defect), 42 U.S.C. § 1983 claims against the City of Cleveland (failure to train) and against Officers Perry and Goza (excessive force), plus state claims (later waived).
The district court granted summary judgment for defendants on all claims; the Fifth Circuit reviewed de novo and affirmed, finding insufficient evidence on product defect/warning and that officers were entitled to qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure-to-warn (Taser)	Warnings were inadequate, especially about chest tasing, and caused the death	Taser provided repeated warnings of serious injury/death; no proof different warnings would have changed officer conduct	Summary judgment for Taser — warnings were adequate and no proximate causation shown
Manufacturing defect (Taser)	Taser device was defective and caused death	Plaintiff produced only speculation, no evidence of a manufacturing defect	Summary judgment for Taser — no evidentiary support for defect claim
Monell failure-to-train (City)	City training was inadequate and deliberately indifferent; CPD systematically targeted Black males with Tasers	Plaintiff failed to specify how training was deficient or provide evidence of systemic targeting beyond bare statistics	Summary judgment for City — no specific evidence of deficient training or deliberate indifference
Excessive force / qualified immunity (Officers)	Use of Tasers and alleged chokehold constituted excessive, unreasonable force	Officers acted reasonably given flight, resistance, ignored warnings, attempts to seize weapons; qualified immunity applies	Summary judgment for officers — force not clearly unreasonable; qualified immunity bars §1983 claim

Young v. Equifax Credit Information Servs., Inc., 294 F.3d 631 (5th Cir.) (standard of review for summary judgment)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S.) (summary judgment and drawing inferences for nonmovant)
Saucier v. Katz, 533 U.S. 194 (U.S.) (two-step qualified immunity framework)
Pearson v. Callahan, 555 U.S. 223 (U.S.) (courts may address qualified immunity prongs in either order)
Rockwell v. Brown, 664 F.3d 985 (5th Cir.) (elements of excessive-force claim)
Pineda v. City of Houston, 291 F.3d 325 (5th Cir.) (elements for municipal failure-to-train liability)
Roberts v. City of Shreveport, 397 F.3d 287 (5th Cir.) (requirement to plead specific defects in training)
Mace v. City of Palestine, 333 F.3d 621 (5th Cir.) (deadly-force reasonableness when suspect poses serious threat)
Ramirez v. Martinez, 716 F.3d 369 (5th Cir.) (distinguishing Taser cases where suspect was not fleeing)
Newman v. Guedry, 703 F.3d 757 (5th Cir.) (Taser excessive-force analysis)