J.W. Ex Rel. Wikle v. Corporal Carrier
645 F. App'x 263
| 4th Cir. | 2016Background
- Plaintiff J.W., through his father, sued after Corporal Carrier lifted J.W.’s arm during a school seizure and J.W. was injured; district court granted summary judgment for defendants and denied reconsideration.
- Before the lift, Carrier heard J.W. threaten self-harm and observed J.W. tip over a desk near a teacher.
- J.W. resisted initial handcuffing, continued resisting after being handcuffed, attempted to pull his hands free, and kicked Carrier in the thigh.
- Carrier then lifted J.W.’s arm, which resulted in J.W.’s injury.
- The court evaluated the claim under the Fourth Amendment’s objective-reasonableness excessive-force standard and concluded Carrier’s conduct was reasonable under the circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether genuine issues of material fact existed on whether Carrier’s use of force was reasonable under the Fourth Amendment | J.W. contended lifting his arm was excessive and raised factual disputes precluding summary judgment | Carrier argued the lift was reasonable given threats, property disturbance, active resistance, and a kick to the officer | Court held no genuine dispute: force was objectively reasonable under the circumstances |
| Whether denial of reconsideration was improper | J.W. argued the district court should revisit its summary-judgment ruling | Defendants argued there was no new basis to alter the judgment | Court affirmed denial; reconsideration would not change the outcome |
Key Cases Cited
- Jacobs v. N.C. Admin. Office of the Courts, 780 F.3d 562 (4th Cir. 2015) (summary judgment standard and review)
- Thompson v. Potomac Elec. Power Co., 312 F.3d 645 (4th Cir. 2002) (conclusory evidence insufficient to defeat summary judgment)
- Estate of Armstrong ex rel. Armstrong v. Vill. of Pinehurst, 810 F.3d 892 (4th Cir. 2016) (Fourth Amendment excessive-force framework)
- Smith v. Ray, 781 F.3d 95 (4th Cir. 2015) (balancing intrusion against governmental interests in reasonableness analysis)
- Graham v. Connor, 490 U.S. 386 (1989) (objective reasonableness standard for seizures and force)