Erin Lincoln v. City of Colleyville, Texas
887 F.3d 190
5th Cir.2018Background
- December 26, 2013: police responded to a report that John Lincoln, armed, threatened his mother; John and his daughter Erin were inside the house. SWAT arrived and shot John at the front door; he died.
- Erin rushed to her father after the shooting; SWAT physically removed and handcuffed her, then placed her in the back of a police car.
- About two hours after the shooting, Officer Sandra Scott transported Erin to the Colleyville Police Department; Detective Kyle Meeks and Ranger Clair Barnes conducted an interview at the station.
- Erin sat at the station roughly 2 hours 17 minutes; the interview component lasted ~1 hour 43 minutes; cumulative detention from removal at scene through station activities was about four hours.
- Erin sued under 42 U.S.C. § 1983 alleging a Fourth Amendment seizure (unreasonable investigatory detention) and asserted the officers were not entitled to qualified immunity. The district court granted summary judgment to the officers; the Fifth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Erin was seized in violation of the Fourth Amendment | Detention in the police car and transport to station for questioning was a seizure and was unreasonable because it lasted ~4 hours without probable cause | Detention was reasonable to secure the scene and obtain information from the sole witness; Erin was compliant and officers had safety/investigatory justifications | Court: Officers did seize Erin and detention was unreasonable (Fourth Amendment violated) |
| Whether the officers are entitled to qualified immunity | The unlawfulness of detaining a compliant sole witness to a police shooting was clearly established | No controlling precedent clearly prohibited detaining a sole, compliant witness under these facts; officers acted under plausible investigatory and safety needs | Court: Right was not clearly established in these circumstances; officers entitled to qualified immunity and summary judgment affirmed |
Key Cases Cited
- Lincoln v. Turner, 874 F.3d 833 (5th Cir. 2017) (discusses tiers of citizen–police contact and reasonableness of witness detention)
- Walker v. City of Orem, 451 F.3d 1139 (10th Cir. 2006) (90-minute detention of witnesses after a police shooting found unreasonable)
- Maxwell v. Cty. of San Diego, 708 F.3d 1075 (9th Cir. 2013) (five-hour detention of witnesses without suspicion held unreasonable; detentions must be minimally intrusive)
- Wesby v. District of Columbia, 138 S. Ct. 577 (2018) (qualified-immunity standard and requirement that law be ‘clearly established’ in particularized factual context)
- Dunaway v. New York, 442 U.S. 200 (1979) (police may not, absent probable cause or consent, seize and transport a person to the station for prolonged interrogation)
- Davis v. Mississippi, 394 U.S. 721 (1969) (limits on police seizure and transport for interrogation)
- United States v. Place, 462 U.S. 696 (1983) (Supreme Court has not endorsed detentions longer than 90 minutes in certain investigatory contexts)