Jonathan Hedgpeth v. Ammar Rahim
893 F.3d 802
| D.C. Cir. | 2018Background
- On March 2, 2015, D.C. officers Rahim and Rider encountered Jonathan Hedgpeth near a bar after reports of someone hitting people on the street; Hedgpeth was slurring, nonresponsive, and belligerent.
- Officers allege Hedgpeth had pushed a stranger; Hedgpeth disputes aspects of who was pushed and does not remember the arrest; witness Marcus Lee testified Hedgpeth was intoxicated and "hard to handle."
- After repeated warnings and orders to put his hands behind his back, Officer Rahim performed a takedown; Hedgpeth’s head struck a bar window, causing concussion-like injuries.
- No criminal charges were filed. Hedgpeth sued under 42 U.S.C. § 1983 claiming unlawful arrest and excessive force; the officers moved for summary judgment based on qualified immunity.
- The district court granted summary judgment for the officers; the D.C. Circuit affirmed, holding officers entitled to qualified immunity as to both the arrest (probable cause/public intoxication) and the use of force (no clearly established law violated).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of warrantless arrest (probable cause) | Hedgpeth: arrest unsupported by probable cause because he did not pose danger and officers misidentified who was pushed | Officers: probable cause existed for public intoxication (intoxicated and dangerous) or alternatively disorderly conduct/assault/affray | Held: Qualified immunity; officers reasonably believed probable cause for public intoxication existed |
| Application of D.C. public intoxication statute | Hedgpeth: behavior was at most passive verbal belligerence, not "dangerous" intoxication | Officers: slurred speech, incoherence, noncompliance, crowd-forming and witness saying "hard to handle" supported belief of danger | Held: Officers reasonably believed Hedgpeth was intoxicated and posed danger; arrest reasonable for qualified-immunity purposes |
| Excessive-force claim — intent to injure (gratuitous force) | Hedgpeth: Rahim intended to slam Hedgpeth’s head into the window during takedown | Officers: no intent to injure; impact was incidental or Hedgpeth stepped away; witness testimony undermines intentional-slamming theory | Held: No evidence supports intent to injure; court resolves that factual theory against Hedgpeth |
| Excessive-force claim — objective reasonableness of takedown | Hedgpeth: takedown was excessive given misdemeanor nature and injury | Officers: takedown reasonable to subdue a belligerent, noncompliant, potentially dangerous suspect | Held: Even if force was debatable, law was not "clearly established" that such a takedown was unconstitutional under these facts; qualified immunity applies |
Key Cases Cited
- Mullenix v. Luna, 136 S. Ct. 305 (2015) (qualified-immunity framework; context-specific clearly established law requirement)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified-immunity two-step and discretion to decide order of inquiries)
- White v. Pauly, 137 S. Ct. 548 (2017) (need for precedent to place constitutional question beyond debate; avoid high-level generalizations)
- Kisela v. Hughes, 138 S. Ct. 1148 (2018) (excessive-force analysis; importance of closely similar precedent for clearly established rule)
- Graham v. Connor, 490 U.S. 386 (1989) (objective-reasonableness standard for excessive force)
- Wardlaw v. Pickett, 1 F.3d 1297 (D.C. Cir. 1993) (probable-cause/qualified immunity; force against a shouting, approaching individual upheld)
- Johnson v. District of Columbia, 528 F.3d 969 (D.C. Cir. 2008) (officer force analysis; assessing nongratuitous force)
- Scott v. District of Columbia, 101 F.3d 748 (D.C. Cir. 1996) (use of force during arrest not clearly excessive where suspect acted belligerently)