Estate of Wayne A. Jones v. City of Martinsburg, WV, 961 F.3d 661

Background

In March 2013 Martinsburg police stopped Wayne Jones, a 50‑year‑old Black man experiencing homelessness and diagnosed with schizophrenia, for walking in the street rather than on the sidewalk.
Officers tased Jones multiple times, pursued and wrestled him to the ground, placed him in a choke hold (audio reflects gurgling), and at some point Staub reported seeing a knife; Jones had a small fixed blade knife tucked into his right sleeve.
After officers simultaneously stepped back about five feet, five officers formed a semicircle and fired 22 rounds, killing Jones; most bullets entered his back/buttocks.
The Estate brought § 1983 claims: (1) Fourth Amendment excessive/deadly force against the officers; (2) Monell claim against the City for failure to train.
Procedural history: the case had multiple discovery/admissions disputes and prior appeals; on remand the district court granted summary judgment to defendants (qualified immunity for officers; Monell dismissal).
The Fourth Circuit reversed the grant of qualified immunity (vacated dismissal of officers) but affirmed summary judgment on the Monell claim and remanded for trial on the excessive‑force claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers are entitled to qualified immunity because Jones was "secured" when shot	Jones was pinned/physically restrained by officers and therefore secured; officers cannot constitutionally release and then shoot a secured person	Jones was not secured: not handcuffed, had a knife, and admitted to stabbing an officer; thus force was reasonable	Reversed district court: genuine fact issue exists whether Jones was secured; qualified immunity inappropriate at summary judgment
Whether officers are entitled to qualified immunity because Jones was "incapacitated" when shot	After multiple tasings, blows, choke hold and audible gurgling, Jones was immobilized/helpless (left arm fell limply) and thus shooting him was unconstitutional	Jones failed to drop the knife on commands and remained a threat; prior cases place this in a gray area supporting immunity	Reversed district court: jury could find Jones incapacitated; genuine issue precludes qualified immunity
Whether the City is liable under Monell for failure to train based on this single incident	The shooting demonstrates need for more/different training and poor implementation of use‑of‑force policy	City had an aggression response policy; a single incident is insufficient to show deliberate indifference or municipal policy/failure	Affirmed: single incident alone insufficient; Estate did not show deliberate indifference or obvious training deficiency triggering Canton exception

Key Cases Cited

Tennessee v. Garner, 471 U.S. 1 (U.S. 1985) (constitutional limits on deadly force against fleeing suspects)
Graham v. Connor, 490 U.S. 386 (U.S. 1989) (objective‑reasonableness standard for excessive force claims)
White v. Pauly, 137 S. Ct. 548 (U.S. 2017) (general Fourth Amendment precedent does not alone create clearly established law outside an obvious case)
Henry v. Purnell, 652 F.3d 524 (4th Cir. 2011) (focus on the moment force is employed for excessive‑force analysis)
Kane v. Hargis, 987 F.2d 1005 (4th Cir. 1993) (force unreasonable where suspect pinned to ground and further force inflicted)
Meyers v. Baltimore Cty., 713 F.3d 723 (4th Cir. 2013) (continued taser use unreasonable once suspect restrained and no longer resisting)
Young v. Prince George’s Cty., 355 F.3d 751 (4th Cir. 2004) (being armed does not automatically justify all force; force against already restrained suspect unreasonable)
Brockington v. Boykins, 637 F.3d 503 (4th Cir. 2011) (deadly force unlawful once suspect is injured, helpless, and immobilized)
Wilson v. Prince George’s County, 893 F.3d 213 (4th Cir. 2018) (distinguishing facts that create qualified immunity from those that do not)
Kisela v. Hughes, 138 S. Ct. 1148 (U.S. 2018) (Supreme Court: qualified immunity can apply when facts present a close/uncertain threat assessment)
City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (municipal liability for failure to train requires deliberate indifference; Canton exception narrow)
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (U.S. 1978) (municipal liability cannot be based on respondeat superior)
Semple v. City of Moundsville, 195 F.3d 708 (4th Cir. 1999) (single incident rarely establishes municipal custom or deliberate indifference)
Bd. of Cty. Comm’rs of Bryan Cty. v. Brown, 520 U.S. 397 (U.S. 1997) (clarifies Canton exception)