Eldredge v. TOWN OF FALMOUTH, MA, 662 F.3d 100

Eldredge, walking with a friend on Sandwich Road after 10:50 p.m., was struck by a police cruiser responding to a 911 domestic disturbance call involving his ex-girlfriend.
Three Falmouth police officers responded: Maguire driving ahead, Simoneau behind, and Harris in a separate car; Maguire's cruiser approached Eldredge and Dubois on the roadside.
Maguire abruptly braked, shined a spotlight, and ordered the pedestrians to stop; shortly after, Simoneau's cruiser rear-ended Maguire's vehicle, propelling Eldredge into the air and injuring him.
Eldredge sued under 42 U.S.C. § 1983 for unreasonable seizure, arguing Maguire's stop lacked justification and Simoneau's collision was unlawful; he also asserted municipal training claims and state-law claims.
The district court dismissed the federal § 1983 claims on qualified immunity grounds, leaving only state-law claims.
On appeal, the First Circuit affirmed, concluding Simoneau did not seize Eldredge intentionally, and Maguire was entitled to qualified immunity because reasonable suspicion for an investigatory stop could have existed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Simoneau's act of striking Eldredge constitute a Fourth Amendment seizure?	Eldredge contends seizure occurred via intentional contact by Simoneau.	Simoneau did not intend to seize; collision was unintentional and not an intentional stop.	No seizure under Fourth Amendment; no intentional termination of movement by Simoneau.
Was Maguire's stop of Eldredge supported by reasonable suspicion and thus protected by qualified immunity?	Eldredge does not match the 911 caller's suspect profile and was not on a defined route; stop was unlawful.	Facts could reasonably support suspicion that Eldredge was the caller's ex-boyfriend; stop was reasonable.	Qualified immunity applies; reasonable suspicion was arguable, so the stop was not clearly unlawful.
Is Eldredge's theory of joint tortfeasor liability against Simoneau appropriate under § 1983?	Simoneau acted as part of a team with Maguire to respond to the 911 call, making him liable.	Gutierrez-Rodriguez does not support imputing liability for a constitutional injury from mere involvement in a squad; actions were not a deliberate, coordinated plan to injure.	Joint tortfeasor theory not applicable to impose § 1983 liability on Simoneau.

Brower v. County of Inyo, 489 U.S. 593 (1989) (seizure requires intentional termination of movement)
Landol-Rivera v. Cruz Cosme, 906 F.2d 791 (1st Cir. 1990) (definition of seizure and governmental termination of movement)
Horta v. Sullivan, 4 F.3d 2 (1st Cir. 1993) (no seizure where pursuit ends by non-intentional means)
Gutierrez-Rodriguez v. Cartagena, 882 F.2d 553 (1st Cir. 1989) (joint tortfeasor doctrine in police squad context; proximate cause not automatic liability)
United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion standard for stops; reasonable grounds need not be certain)
Terry v. Ohio, 392 U.S. 1 (1968) (reasonable suspicion required for investigatory stop)
Graham v. Connor, 490 U.S. 386 (1989) (reasonableness in police use of force; split-second judgments allowed)
New Jersey v. T.L.O., 469 U.S. 325 (1985) (reasonable suspicion standard in school search context; probability not certainty)
McInnis v. Maine, 638 F.3d 18 (1st Cir. 2011) (qualified immunity existence if violation is arguable)
Pearson v. Callahan, 555 U.S. 223 (2009) (two-prong qualified immunity test; need not be sequential)
Maldonado v. Fontanes, 568 F.3d 263 (1st Cir. 2009) (two-prong test for qualified immunity; clearly established right analysis)
LaFrance v. United States, 879 F.2d 1 (1st Cir. 1989) (context on investigative stops and reasonableness)