Goodwin Ex Rel. Nall v. City of Painesville, 781 F.3d 314

Nalls hosted a gathering; police responded to a noise complaint at their apartment building in the early morning hours of July 26, 2010.
Officers Soto and Hughes returned, confronted Mr. Nall, and tasered him for a total of 26 seconds; he went into cardiac arrest and sustained anoxic brain injury.
Ms. Nall was arrested for disorderly conduct; both Nalls’ charges were later dismissed for lack of exigent circumstances.
Officers sought summary judgment on qualified immunity for federal claims and immunity under Ohio law for state claims; district court denied on all contested claims.
The Sixth Circuit affirmed, addressing four asserted constitutional violations and related state-law issues.
The court viewed facts in the Nalls’ favor for purposes of the qualified-immunity analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force against Nall	Nall suffered prolonged tasering after he ceased resisting.	Prolonged tasering was reasonable given perceived threat and resistance.	Qualified immunity not granted; possible Fourth Amendment violation presented to jury.
Failure to protect during tasering	Hughes and Collins failed to intervene to stop excessive force.	No duty to intervene if no obvious risk or opportunity to act.	Qualified immunity denied for Hughes and Collins; jury could find failure to protect.
Warrantless entry into the Nalls' home (Rohrig/ exigent circumstances)	Entry was unlawful absent exigent circumstances.	Rohrig exception or exigent-threat theory could justify entry.	Rohrig not satisfied; genuine factual dispute on exigent-circumstances; entry not clearly justified as of summary judgment.
Ms. Nall's disorderly-conduct arrest	Probable cause lacked for arrest; language/actions were protective response to unlawful entry.	Probable cause existed based on Ohio 2917.11(A)(2) and perceived nuisance.	Probable-cause determination issue for summary judgment; cannot conclude Ms. Nall's conduct was sufficiently reckless.

Graham v. Connor, 490 U.S. 386 (1989) (objective reasonableness standard for excessive force)
St. John v. Hickey, 411 F.3d 762 (6th Cir. 2005) (two-tiered qualified-immunity framework)
Landis v. Baker, 297 F. App’x 453 (6th Cir. 2008) (gratuitous taser use violates clearly established rights)
Shreve v. Jessamine Cnty. Fiscal Court, 453 F.3d 681 (6th Cir. 2006) (prolonged force after minimal resistance violates rights)
Adams v. Metiva, 31 F.3d 375 (6th Cir. 1994) (mace deployment and excessive-force principles; failure-to-protect context)
Cockrell v. City of Cincinnati, 468 F. App’x 491 (6th Cir. 2012) (distinguishes concealed/flight scenarios from home-entry context)
Payton v. New York, 445 U.S. 573 (1980) (home-entry warrants principles; warrantless entry presumptively unreasonable)
Rohrig, 98 F.3d 1506 (6th Cir. 1996) (nuisance/contextualized exigent-entry exceptions; narrowly tailored)
United States v. Williams, 354 F.3d 497 (6th Cir. 2003) (recognized exigent circumstances framework)
DeFillippo v. DeKalb, 443 U.S. 97 (1979) (probable cause standard for arrest)
Devenpeck v. Alford, 543 U.S. 146 (2004) (flexible probable-cause inquiry)