Edward Schoettle v. Jefferson County
2015 U.S. App. LEXIS 9729
| 8th Cir. | 2015Background
- Edward Schoettle, insulin-dependent diabetic, was found in his truck on a highway shoulder after signs of hypoglycemia on Nov 6, 2010
- Deputies Hudson and Peifer removed Schoettle from the vehicle after observing impairment and potential intoxication
- Schoettle allegedly resisted, was pepper-sprayed, and received head/body strikes during arrest
- A gun in Schoettle’s waistband was removed; EMS later treated him for hypoglycemia and a nosebleed
- Schoettle sued under 42 U.S.C. § 1983 and state-law claims alleging excessive force, failure to provide medical care, supervisory and municipal liability, and assault/battery
- District court granted summary judgment to deputies on all claims; the Eighth Circuit affirmed
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force whether the force used was reasonable | Schoettle asserts disputed facts on suspicion, resistance level, and medical condition | Hudson/Peifer acted with reasonable force given suspected DWI and resistance | Qualified immunity; force reasonable under Graham |
| Assault and battery under Missouri law whether force exceeded reasonableness | Officers used excessive force in pre-arrest conduct | Force was not more than reasonably necessary | Summary judgment upheld; no tortious force |
| Supervisory/municipal liability whether County/Sheriff liable for underlying conduct | Failure to instruct/supervise caused constitutional violation | No underlying violation by officers; no liability | No supervisory/municipal liability; district court affirmed |
Key Cases Cited
- Graham v. Connor, 490 F.3d 386 (Supreme Court 1989) (unreasonable force requires objective reasonableness under Fourth Amendment)
- Janis v. Biesheuvel, 428 F.3d 795 (8th Cir. 2005) (impaired-driver threat; potential medical cause not always known to officers)
- Wertish v. Krueger, 433 F.3d 1062 (8th Cir. 2006) (diabetic condition not always evident; objective reasonableness of force)
- Carpenter v. Gage, 686 F.3d 644 (8th Cir. 2012) (injury/medical need considerations during restraint; use of force assessed at time of incident)
- United States v. Lawhorn, 735 F.3d 817 (8th Cir. 2013) (reasonable suspicion and Terry stop standard; totality of circumstances)
- United States v. Givens, 763 F.3d 987 (8th Cir. 2014) (fact-specific analysis of investigative stops and force)
- United States v. Phillips, 679 F.3d 995 (8th Cir. 2012) (authority on order for subject to exit during investigatory stop)