Gabriel Coker v. Arkansas State Police
2013 U.S. App. LEXIS 22420
8th Cir.2013Background
- At 2:30 a.m. on Feb. 12, 2009, Officer Brad Cartwright pursued Gabriel Coker on a motorcycle after clocking speeds up to 102–150+ mph and observing no license plate; Coker failed to stop during a ~3-minute pursuit.
- Cartwright bumped Coker’s motorcycle, causing it to tip; dash-cam video records events up to Coker falling and running to the road shoulder but not the subsequent struggle (audio unclear).
- Out of camera view, the parties’ accounts diverge: Cartwright says he kicked Coker, sat on him, and possibly struck him with a metal flashlight while subduing a resisting suspect; Coker says he complied, was kicked, struck with the flashlight (breaking cheek bones), and hit again while handcuffed.
- The district court granted summary judgment dismissing the Arkansas State Police (Eleventh Amendment immunity) and granted Cartwright qualified immunity on Coker’s individual-capacity Fourth Amendment excessive-force claim; it also denied Coker leave to amend his complaint as untimely.
- The Eighth Circuit affirmed the Eleventh Amendment ruling and denial to amend, but reversed the grant of qualified immunity to Cartwright, finding genuine disputes of material fact about the use of force after dash-cam view that preclude resolution as a matter of law.
Issues
| Issue | Plaintiff's Argument (Coker) | Defendant's Argument (Cartwright/State) | Held |
|---|---|---|---|
| State sovereign immunity (Eleventh Amendment) | State police liable under §1983 | State immune from suit | Affirmed — Arkansas State Police immune |
| Official-capacity claim for prospective relief | Seeks relief against Cartwright’s official conduct | Official-capacity claim barred by sovereign immunity absent proper prospective relief claim | Affirmed — no cognizable prospective relief; barred |
| Qualified immunity on individual-capacity excessive-force claim | Force after dash-cam view was excessive; broken cheek bones show severity and disputed facts preclude summary judgment | Use of force was reasonable during arrest; entitled to qualified immunity | Reversed — genuine factual disputes about post-video force preclude qualified immunity determination |
| Denial of late motion to amend complaint | Amendment should be allowed (new theories) | Motion untimely; no good cause under scheduling order | Affirmed — district court did not abuse discretion denying amendment |
Key Cases Cited
- Scott v. Harris, 550 U.S. 372 (court may reject blatantly contradicted version of events at summary judgment)
- Graham v. Connor, 490 U.S. 386 ( Fourth Amendment reasonableness standard for use of force)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity framework)
- Monroe v. Ark. State Univ., 495 F.3d 591 (Eleventh Amendment and official-capacity relief limits)
- Kelly v. Bender, 23 F.3d 1328 (use of flashlight as weapon is jury question)
- Loch v. City of Litchfield, 689 F.3d 961 (qualified immunity standards in §1983 cases)
- Montoya v. City of Flandreau, 669 F.3d 867 (credibility determinations reserved for jury at summary judgment)
- Popoalii v. Corr. Med. Servs., 512 F.3d 488 (district court discretion on motions to amend under Fed. R. Civ. P. 16)
- Mann v. Yarnell, 497 F.3d 822 (severity of injuries relevant to excessive-force analysis)