Jeff Courtright v. City of Battle Creek, 839 F.3d 513

Background

Police officers Wolf and Rathjen responded to an anonymous phone tip that Courtright had come out of his motel room with a gun and threatened to shoot another resident’s dog.
Courtright told officers he had been visiting friends and was not in his room or armed; Wolf arrested him for felonious assault.
During arrest Wolf and Rathjen handcuffed Courtright despite his statements that prior rotator-cuff injuries and shoulder surgeries prevented him from placing his hands behind his back; Courtright complained of pain while handcuffed.
Courtright was jailed overnight; the prosecutor declined to seek a warrant and he was released the next day.
Courtright sued under 42 U.S.C. § 1983 for excessive force (handcuffing), false arrest, and Monell municipal liability; defendants moved to dismiss on qualified immunity and failure-to-state-a-claim grounds.
District court denied dismissal of federal claims; defendants appealed interlocutorily as to qualified immunity for the officers and challenged the municipal-liability denial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force (handcuffing) — did complaint plausibly allege a Fourth Amendment violation?	Courtright alleged prior shoulder injuries, inability to put hands behind his back, and pain from being handcuffed behind his back.	Defendants said allegations fail to plead physical injury required for a handcuffing claim.	Court: Allegations permit reasonable inference that handcuffing aggravated prior injuries and caused physical pain; claim survives dismissal.
Qualified immunity — was the right clearly established?	Freedom from excessively forceful/unduly tight handcuffing is clearly established in the Sixth Circuit.	Defendants urged more particularized precedent was required.	Court: Right was clearly established; denial of qualified immunity on excessive-force claim affirmed.
False arrest — was there probable cause at time of arrest?	Caller’s tip alone was insufficient; Courtright argued no corroboration and exculpatory statements were ignored.	Defendants argued the tip was an eyewitness report creating probable cause.	Court: Single anonymous phone tip lacked indicia of reliability and no corroboration or investigation was alleged; probable cause not plausibly established; false-arrest claim survives.
Municipal liability (Monell) — can the City be held?	City liability pleaded; plaintiff urged discovery to develop policy/training facts.	Defendants argued no underlying constitutional violation and insufficient municipal allegations.	Court: Because constitutional claims against officers survive, appellate court lacked jurisdiction to resolve Monell issue now; appeal of municipal claim dismissed for lack of jurisdiction.

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (establishes pleadings/qualified-immunity interlocutory appeal principles)
Baynes v. Cleland, 799 F.3d 600 (6th Cir.) (freedom from excessively forceful or unduly tight handcuffing is clearly established)
Morrison v. Board of Trustees, 583 F.3d 394 (6th Cir.) (lesser injuries — bruising, wrist marks, pain — can support handcuffing excessive-force claims)
Neague v. Cynkar, 258 F.3d 504 (6th Cir.) (no physical injury, handcuffing alone insufficient at summary judgment)
Beck v. Ohio, 379 U.S. 89 (probable cause standard for arrest)
Ahlers v. Schebil, 188 F.3d 365 (6th Cir.) (eyewitness statements generally reliable; corroboration can bolster probable cause)
Gardenhire v. Schubert, 205 F.3d 303 (6th Cir.) (informant’s allegation may provide reasonable suspicion but not necessarily probable cause absent corroboration)
Wesley v. Campbell, 779 F.3d 421 (6th Cir.) (qualified-immunity standards at motion-to-dismiss and probable-cause discussion)
Martin v. Heideman, 106 F.3d 1308 (6th Cir.) (excessive handcuffing claim viability with numbness/swelling allegations)