Dontrell Stephens v. Ric Bradshaw
879 F.3d 1157
| 11th Cir. | 2018Background
- On Sept. 13, 2013 Deputy Adams Lin shot Dontrell Stephens four times during a traffic stop in Palm Beach County, rendering Stephens permanently paraplegic; parties dispute whether Stephens posed a threat.
- Stephens sued under 42 U.S.C. § 1983 (excessive force) against Lin and asserted Monell liability against Sheriff Ric Bradshaw; state-law battery claim also pursued.
- District court granted summary judgment to Bradshaw on the Monell claim, denied summary judgment to Lin on qualified immunity, and the case proceeded to jury trial on excessive force and battery-related liability.
- Jury found Lin used excessive force and awarded roughly $23.1 million; final judgment entered jointly and severally against Lin and Bradshaw.
- Post-trial, defendants sought a new trial, arguing erroneous jury instructions (including ones bearing on qualified immunity); district court denied in part.
- Eleventh Circuit: affirmed summary judgment for Bradshaw on Monell; vacated part of judgment and remanded for a new trial because a jury instruction improperly conflated excessive-force factual findings with the legal question of qualified immunity, depriving Lin of a court resolution of that defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sheriff Bradshaw is liable under Monell for Lin’s use of force | Stephens: Bradshaw’s routine, uncritical ratification of deputies’ force and investigatory failures created a custom causing the shooting | Bradshaw: No pattern of prior unconstitutional shootings, proper investigations occurred, and a single incident without ratification cannot establish Monell causation | Affirmed for Bradshaw: summary judgment proper—Stephens failed to show necessary pattern, causation, or municipal deliberate indifference |
| Whether the district court’s jury instructions improperly resolved qualified immunity | Stephens: jury instruction properly addressed excessive-force fact questions; jury could find liability | Lin/Bradshaw: instruction conflated jury fact-finding with the legal question of qualified immunity and denied court decision on entitlement to immunity | Reversed as to Lin: instruction was erroneous and deprived Lin of his right to have the court decide qualified immunity; new trial ordered |
| Whether denial of special interrogatories and certain requested instructions was reversible error | Stephens: not reversible because instructions given covered substance and any errors were harmless | Defendants: special interrogatories regarding the factual predicates of qualified immunity and a "20/20 hindsight" instruction were necessary to preserve factual findings for the court’s legal ruling | Court: failure to submit special interrogatories was error here because jury instructions misled and foreclosed court determination of qualified immunity; new trial required |
| Standard and allocation of fact vs. law in qualified immunity contexts | N/A (dispute centers on application) | N/A | Court reiterated that factual determinations (who, what, when) are for the jury; entitlement to qualified immunity is a legal question for the judge using the jury’s factual findings — the trial court misapplied this separation here |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (establishes objective qualified immunity standard)
- Mitchell v. Forsyth, 472 U.S. 511 (qualified immunity is immunity from suit; should be decided early)
- Saucier v. Katz, 533 U.S. 194 (distinguishes factual reasonableness from legal question whether right was clearly established)
- Monell v. Department of Social Services, 436 U.S. 658 (municipal liability requires policy/custom causing constitutional violation)
- Connick v. Thompson, 563 U.S. 51 (high standard for municipal liability; need for stringent proof of fault)
- Johnson v. Breeden, 280 F.3d 1308 (11th Cir.) (qualified immunity as legal issue but may turn on facts; use of special interrogatories)
- Cottrell v. Caldwell, 85 F.3d 1480 (11th Cir.) (qualified immunity should not be submitted to the jury; jury resolves historical facts)
- Gowski v. Peake, 682 F.3d 1299 (11th Cir.) (motions for new trial based on erroneous jury instructions reviewed for abuse of discretion)