Hunt v. Massi
5 F. Supp. 3d 160
D. Mass.2014Background
- Arrest of Brian Hunt on June 6, 2011 pursuant to a warrant for an unpaid traffic fine; payment had been made but not recorded.
- Arrest conducted by Falmouth officers Massi and Porter at Hunt home; Hunt to be detained after being informed of arrest.
- Hunt had recently undergone surgery and requested front-handcuffing; officers handcuffed behind his back and used force including pushing to floor and kneeling.
- Video and hospital encounter show forceful handling; Hunt taken to police station and later released on own recognizance; he later faced assault and resisting arrest charges.
- Hunt alleged the arrest was pretextual and sought damages for excessive force, malicious prosecution, Monell claims, and related state-law claims; court granted summary judgment on several counts and proceeded on others.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force in arrest of Hunt | Hunt asserts back-handcuffing and forceful handling violated Fourth Amendment. | Officers claim use of reasonable force given arrest context. | Qualified immunity not barred; triable issue on excessive force. |
| Malicious prosecution related to post-arrest charges | Charges for resisting arrest and assault/battery lacked probable cause. | Prosecution based on disputed statements; probable cause exists. | Summary judgment denied for post-altercation malicious prosecution. |
| Malicious prosecution tied to the June 6 arrest | Arrest lacked probable cause and violated rights. | Arrest supported by facially valid warrant; proper authority. | Arrest-based malicious prosecution claim granted (no violation). |
| Massachusetts Civil Rights Act claim against officers | MCRA violations paralleled §1983 excessive force. | MCRA requires immunity analysis consistent with §1983. | No qualified immunity; MCRA claim survives against officers. |
| Battery claim against officers | Excessive force constitutes common-law assault/battery. | Qualified immunity analysis governs battery claim as §1983 derivative. | Battery claim survives summary judgment. |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (1989) (excessive force standard under Fourth Amendment)
- Scott v. Harris, 550 U.S. 372 (2007) (video as evidence in excessive force analysis; judicial assessment of evidence scope)
- Aceto v. Kachajian, 240 F. Supp. 2d 121 (D. Mass. 2003) (front-handcuffing and injury considerations under qualified immunity)
- Raiche v. Pietroski, 623 F.3d 30 (1st Cir. 2010) (probable cause and excessive force analysis in §1983 context)
- Nieves v. McSweeney, 241 F.3d 46 (1st Cir. 2001) (elements of malicious prosecution; absence of probable cause must be shown)
- Anderson v. Creighton, 483 U.S. 635 (1987) (standard for reasonable officer under qualified immunity—objective reasonableness)
- Roche v. John Hancock Mutual Life Ins. Co., 81 F.3d 249 (1st Cir. 1996) (probable cause standards; objective view required)
- Saucier v. Katz, 533 U.S. 194 (2001) (three-step qualified-immunity framework (clarified by Pearson))
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework discretionary applicability)