Jason Findlay v. Jon Lendermon, 2013 U.S. App. LEXIS 12012

Findlay and Howey are neighbors; Howey suspected Findlay of trespass and vandalism.
Findlay found a camcorder near the property line and filed an abandoned property report; Lendermon responded.
Howey and Lorton (Howey’s son-in-law) admitted ownership of the camcorder and had placed it to monitor alleged trespass.
Camcorder captured Findlay admitting knowledge of Howey’s warning against trespass; deputy decided to seize camcorder as evidence.
During seizure, Findlay removed the memory chip; dispute over whether Lendermon tackled Findlay or Findlay dropped/held the chip.
Findlay alleged excessive force; district court denied summary judgment on that claim, but granted on wrongful seizure and false arrest; this court reversed on qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lendermon’s tackling Findlay violated clearly established rights.	Findlay: rights clearly established; tackling was excessive force.	Lendermon: reasonable mistake; qualified immunity applies; no clearly established right tailored to these facts.	Lendermon entitled to qualified immunity; no clearly established right shown

Saucier v. Katz, 533 U.S. 194 (Supreme Court 2001) (rejected single-analysis approach; separate steps for constitutional question and immunity)
Anderson v. Creighton, 483 U.S. 635 (Supreme Court 1987) (objective reasonable belief governs qualified immunity when mistaken as to legality)
Graham v. Connor, 490 U.S. 386 (Supreme Court 1989) (excessive-force inquiry guided by objective reasonableness under totality of circumstances)
Chelios v. Heavener, 520 F.3d 678 (7th Cir. 2008) (plainly excessive force standard for establishing clearly established rights)
Catlin v. City of Wheaton, 574 F.3d 361 (7th Cir. 2009) (clarifies distinction between substantive standard and qualified-immunity analysis)
Abbott v. Sangamon Cnty., 705 F.3d 706 (7th Cir. 2013) (plaintiff must show a sufficiently analogous case or plainly evident excessive force)