Estate of Hill ex rel. Hill v. Miracle
853 F.3d 306
| 6th Cir. | 2017Background
- In June 2013 Corey Hill suffered severe hypoglycemia (blood glucose 38) and became disoriented and combative while paramedics attempted IV dextrose at his home.
- Four paramedics were restraining Hill after he ripped out an IV and caused blood to spray; Hill continued kicking, swinging fists, and resisted lifesaving treatment.
- Deputy Christopher Miracle arrived, warned Hill, and applied his TASER in drive‑stun mode to Hill’s right thigh for a few seconds; paramedics then reestablished the IV and administered dextrose, after which Hill calmed.
- Hill sued Miracle under 42 U.S.C. § 1983 (excessive force) and for assault and battery under Michigan law; the district court denied summary judgment on the § 1983 and assault/battery claims.
- The Sixth Circuit reversed: it held Miracle did not use excessive force (so qualified immunity applied) and that Miracle was entitled to governmental immunity on the state assault/battery claim; the case was remanded with instructions to dismiss with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miracle used excessive force in violation of the Fourth Amendment by tasing Hill during a medical emergency | Hill: TASER use was excessive because he was not committing a crime or being arrested and less forceful alternatives existed | Miracle: TASER was needed to protect paramedics and to permit life‑saving treatment of Hill during a violent hypoglycemic episode | Court: No excessive force; use was objectively reasonable under the circumstances and qualified immunity applies |
| Whether the Fourth Amendment right was clearly established such that qualified immunity is unavailable | Hill: prior law prohibits tasing a non‑arrested, non‑threatening person | Miracle: no controlling precedent clearly forbade tasing in a medical‑emergency context where responders faced danger and needed to render aid | Court: Not clearly established; no prior case squarely prohibited such conduct; qualified immunity applies |
| Whether Miracle is entitled to governmental immunity for assault and battery under Michigan law | Hill: TASER use constituted an intentional tort not shielded by immunity | Miracle: Actions were within employment scope, in good faith, discretionary, so governmental immunity applies (Odom standard) | Court: Miracle entitled to governmental immunity; no reasonable jury could find bad faith or malice |
Key Cases Cited
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework)
- Graham v. Connor, 490 U.S. 386 (objective‑reasonableness test for excessive force)
- Kent v. Oakland County, 810 F.3d 384 (6th Cir. qualified‑immunity analysis)
- Rudlaff v. Gillispie, 791 F.3d 638 (taser use cases distinguishing resisting vs. non‑resisting subjects)
- Caie v. West Bloomfield Township, 485 Fed.Appx. 92 (6th Cir.) (analogous fact pattern upholding single drive‑stun in medical/mental crisis)
- Anderson v. Creighton, 483 U.S. 635 (clearly established rights inquiry)
- Saucier v. Katz, 533 U.S. 194 (legal context for qualified‑immunity/prong two)
- Brosseau v. Haugen, 543 U.S. 194 (fact‑specific nature of excessive‑force qualified‑immunity inquiries)
- Odom v. Wayne County, 760 N.W.2d 217 (Mich.) (standard for governmental immunity for intentional torts)