Guy v. Metropolitan Government of Nashville
687 F. App'x 471
| 6th Cir. | 2017Background
- On Sept. 11, 2013, pretrial detainee Amy Guy asked Officer Janie Romines to see a nurse in a jail day room; Romines ordered her back to her cell and began an open‑handed escort.
- Surveillance video (no audio) shows Guy standing with hands lowered, hesitating and turning toward Romines; Romines sprayed a chemical agent in Guy’s face; Guy reacted, was secured, and later taken for medical evaluation.
- Romines later reported scratches to her forearm, obtained a warrant charging Guy with misdemeanor assault, and provided an affidavit describing Guy as combative; the charge was dismissed at the State’s request.
- Guy sued under 42 U.S.C. § 1983 for excessive force (Fourteenth Amendment), unlawful arrest and malicious prosecution (Fourth Amendment), and deliberate indifference to serious medical needs (Fourteenth Amendment).
- The district court denied Romines’s summary‑judgment motion raising qualified immunity; Romines appealed interlocutorily.
- The Sixth Circuit considered whether (a) force used was objectively unreasonable and clearly established, (b) probable cause supported the arrest/prosecution, and (c) Romines acted with deliberate indifference to Guy’s medical needs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force (Fourteenth Amendment) | Romines sprayed Guy without provocation while Guy offered only passive resistance after asking to see a nurse. | Use of a short burst of spray was minimal force justified to prevent a possible assault. | Denial of qualified immunity affirmed: a reasonable jury could find the spray objectively unreasonable; the right was clearly established. |
| Clearly established law for pretrial excessive‑force claims | Prior Sixth Circuit precedent put officers on notice that using chemical spray on non‑threatening detainees could be unconstitutional. | Kingsley’s objective standard postdates the incident; law was unsettled pre‑Kingsley. | Denial affirmed: existing precedent (Eighth/Fourteenth analogs) made the violative nature of this conduct sufficiently clear in 2013. |
| Unlawful arrest & malicious prosecution (Fourth Amendment) | Romines knowingly made false or reckless statements in the affidavit (e.g., that Guy tried to hit her), so magistrate’s warrant defense fails; disputed mens rea for alleged scratches. | A magistrate‑issued warrant supports arrest absent material falsehoods; Romines asserts probable cause based on alleged assault/scratches. | Denial affirmed: disputed material facts exist about whether statements were false/material and whether probable cause existed to believe Guy acted intentionally/knowingly/recklessly. |
| Deliberate indifference to medical need (Fourteenth/Eighth standard) | Romines ignored Guy’s request to see a nurse while Guy was monitored for withdrawal and felt weak/shaky; this delayed care. | Guy did not present evidence of an objectively serious, obviously emergent condition or verifying medical proof of harm from any delay. | Denial reversed: qualified immunity granted to Romines because evidence fails to show an objectively serious need or a detrimental effect from any delay. |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (establishing modern qualified immunity standard)
- Ashcroft v. al‑Kidd, 563 U.S. 731 (plaintiff must show right was clearly established)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity two‑step and discretion to address prongs)
- Johnson v. Jones, 515 U.S. 304 (limits interlocutory appeals on factual disputes)
- Kingsley v. Hendrickson, 576 U.S. 389 (objective‑reasonableness standard for pretrial detainees)
- Saucier v. Katz, 533 U.S. 194 (clarifies qualified‑immunity analysis focus on clear notice)
- Whitley v. Albers, 475 U.S. 312 (excessive‑force considerations in custodial settings)
- Farmer v. Brennan, 511 U.S. 825 (subjective component for deliberate indifference)
- Burgess v. Fischer, 735 F.3d 462 (Sixth Circuit on amendment context for detainee claims)
- Williams v. Curtin, 631 F.3d 380 (use of chemical agent may be excessive; discussed as precedent)
- Sykes v. Anderson, 625 F.3d 294 (probable‑cause/malicious‑prosecution standards)
- Blackmore v. Kalamazoo Cty., 390 F.3d 890 (verifying medical evidence required for delay‑in‑treatment claims)