Heather Baker v. City of Trenton, 936 F.3d 523

Kyle Baker, an 18-year-old, exhibited erratic behavior at school after reportedly ingesting LSD; officer observed him unresponsive and he left school before parents were fully apprised.
Kyle’s friend Collin found him alone in his father’s house basement, handed Kyle Collin’s phone so Kyle could speak with his mother, and then reported to the police in person that Kyle had a knife, had taken the phone, and had been threatening his mother.
Dispatch conveyed that Kyle was armed and had threatened his mother; responding officers arrived, received an update that house phone attempts were busy, and believed the mother might still be inside.
Officers entered the unlocked house without a warrant, announced themselves, and found Kyle at the bottom of the basement stairs holding a lawnmower blade; he refused commands and moved up the stairs.
Officers tasered Kyle; Officer Driscoll descended the stairs, fell or was knocked into a seated position, was struck by the blade, and then shot Kyle, who later died; post-shooting the officers discovered the mother was not at the house and a shotgun under Kyle’s bed.
District court granted summary judgment for defendants on three § 1983 claims (warrantless entry, excessive force, municipal liability); Sixth Circuit affirmed, finding exigent circumstances justified entry and that the shooting was objectively reasonable self-defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrantless entry	Officers lacked a warrant and no exigency justified entry because mother was not present and Kyle posed no real danger	Dispatch reports that Kyle was armed and threatening his mother and calls to house were busy; officers reasonably believed immediate aid/protection was needed	Entry justified under exigent-circumstances (risk of danger to others); affirm summary judgment
Use of deadly force	Driscoll used excessive/deadly force unjustifiably; disputed facts about distance and angle undermine self-defense claim	Kyle advanced with a blade, struck Driscoll, and posed an immediate threat of serious harm	Objectively reasonable; no excessive-force violation; affirm summary judgment
Municipal liability (Monell)	City failed to train/discipline officers, causing constitutional violations	No underlying constitutional violations by officers, so no municipal liability	Municipal claim fails because no individual constitutional violation established
Qualified immunity (alternative)	Right was clearly established; immunity not appropriate	Officers entitled to qualified immunity if no constitutional violation or if not clearly established	Court resolved case on merits (no constitutional violations) and did not reach qualified immunity second prong

Payton v. New York, 445 U.S. 573 (1980) (warrantless home entries presumptively unreasonable)
Brigham City v. Stuart, 547 U.S. 398 (2006) (objective test for exigent-entry reasonableness)
Graham v. Connor, 490 U.S. 386 (1989) (objective-reasonableness standard for excessive force)
Tennessee v. Garner, 471 U.S. 1 (1985) (deadly force permissible only if suspect poses significant threat)
Chappell v. City of Cleveland, 585 F.3d 901 (6th Cir. 2009) (deadly force justified where knife-wielding suspect advanced in confined space)
Schreiber v. Moe, 596 F.3d 323 (6th Cir. 2010) (exigent entry reasonable to check on possible victim reported by dispatch)
Bletz v. Gribble, 641 F.3d 743 (6th Cir. 2011) (contrast on facts where retreat possible and dispute over perceived threat)
Goodwin v. City of Painesville, 781 F.3d 314 (6th Cir. 2015) (officers may enter without a warrant to render emergency aid)
Thacker v. City of Columbus, 328 F.3d 244 (6th Cir. 2003) (definition of exigent circumstances)
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires constitutional violation by employees)