Estate of Brackens v. Louisville Jefferson County Metro Government
680 F. App'x 362
| 6th Cir. | 2017Background
- Late-night traffic stop in Jeffersonville, IN escalated into a ~20-minute, high-speed, cross-state chase; driver Rhonda Sullivan led police through dangerous maneuvers before stopping in Louisville, KY.
- Leon Brackens, a middle-aged Black man with sickle-cell anemia and severe osteopenia, was a passenger; he called 911 during the chase saying he was being held against his will and feared for his life.
- Dispatch communications to responding LMPD officers inaccurately reported (among other things) that Brackens had a felony warrant, that occupants were "suicidal and homicidal," and instructed units to use extreme caution.
- At the stop, Sullivan exited and was secured; LMPD officers ordered Brackens out, then opened the passenger door, unbuckled and forcibly removed him, pinned him to the pavement, handcuffed him, and conducted a pat-down.
- Brackens suffered fractures to his left femur and humerus; he later died of unrelated causes and his estate pursued § 1983 excessive-force and related claims.
- The district court granted summary judgment to defendants on qualified-immunity and related grounds; the Sixth Circuit affirmed as to the LMPD officers in their individual capacities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers used excessive force in removing and restraining Brackens | Force was excessive and caused serious injuries; officers should have known he was disabled and unarmed | Force was objectively reasonable given the high-speed chase, violent driving, and dispatch warnings that occupants were dangerous | Use of force was reasonable; qualified immunity applies |
| Whether officers violated clearly established Fourth Amendment rights | Right to be free from such force was clearly established | No clearly established law compelled officers to second-guess contemporaneous safety information | No clearly established violation; qualified immunity protects officers |
| Whether a conspiracy existed to deprive civil rights or hide evidence | Inconsistent records and difficulty obtaining documents indicate a conspiracy | No evidence of class-based animus or agreement to deprive rights; discrepancies insufficient | No genuine issue of material fact supporting conspiracy; claim fails |
| Whether state-law tort and evidence-tampering claims survive | State-law claims for negligence and evidence tampering alleged | Officers entitled to Kentucky qualified immunity; no proof of bad faith or intent to impair evidence | State claims dismissed; qualified immunity under Kentucky law applies |
Key Cases Cited
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework)
- Graham v. Connor, 490 U.S. 386 (Fourth Amendment objective-reasonableness test for excessive force)
- Scott v. Harris, 550 U.S. 372 (treatment of video evidence in summary-judgment review)
- Dunn v. Matatall, 549 F.3d 348 (force to remove motorist after chase reasonable given safety risks)
- White v. Pauly, 137 S. Ct. 548 (officers need not second-guess earlier steps by fellow officers)
- Fox v. DeSoto, 489 F.3d 227 (Graham factors applied by Sixth Circuit)
- Robertson v. Lucas, 753 F.3d 606 (summary-judgment review standards in Sixth Circuit)
- Yanero v. Davis, 65 S.W.3d 510 (Kentucky qualified immunity standard)