Hulet v. County of Tuolumne, 1:23-cv-01217

Plaintiff Grant Hulet was arrested for misdemeanor vehicle infractions in January 2023 and brought to the Tuolumne County jail.
Hulet had recently undergone surgery on his left arm and had a history of back injuries, which he disclosed to the officers during booking.
Officers placed Hulet in a safety cell due to perceived mental health concerns and instructed him to disrobe and put on a safety gown.
A confrontation ensued: Hulet refused to undress, advanced towards Officer Marcus Green, and was taken down forcefully by Green, purportedly aggravating his injuries.
Hulet moved for partial summary judgment against Green on Fourth Amendment excessive force grounds; Green asserted qualified immunity and contested the factual representations.
Video evidence partially captured the incident, but material facts (e.g., verbal warnings, threat level, resistance) remained in dispute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive Force under the Fourth Amendment	Green’s takedown was objectively unreasonable and excessive.	Force was reasonable due to perceived threat and resistance.	Denied summary judgment—disputes of fact remain.
Immediate Threat or Active Resistance	Hulet did not pose an immediate threat or actively resist.	Hulet’s gesture and refusal showed threat/active resistance.	Sufficient factual disputes for a jury to resolve.
Availability of Less Intrusive Alternatives	Officers failed to consider reasonable, less forceful alternatives.	Alternatives were impractical due to operational constraints.	Jury must determine reasonableness in context.
Qualified Immunity	Clearly established law prohibits substantial force in these facts.	Law not clearly established; force was reasonable.	Denied; law was clearly established.

Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
Graham v. Connor, 490 U.S. 386 (objective reasonableness for excessive force)
Tennessee v. Garner, 471 U.S. 1 (balancing test for Fourth Amendment use of force)
Scott v. Harris, 550 U.S. 372 (video evidence can override party testimony on summary judgment)
Deorle v. Rutherford, 272 F.3d 1272 (substantial force on mentally ill, non-threatening plaintiff)
Rice v. Morehouse, 989 F.3d 1112 (takedown as substantial force, requires justification)
Blankenhorn v. City of Orange, 485 F.3d 463 (takedown excessive where threat and resistance are minimal)
Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-prong test)
Kingsley v. Hendrickson, 576 U.S. 389 (use of force on pretrial detainee assessed objectively)