Joshua Amerson v. Waterford Township, 562 F. App'x 484

In 2009, Amerson and Hathaway burglarized a residence; Waterford Township police pursued them.
Stechly and Mahoney handcuffed Amerson after a chase, with Amerson lying on the ground on his stomach and offering no resistance.
Amerson alleges Stechly punched him in the head and kicked him; Stechly denies any such contact.
Amerson subsequently suffered seizures starting around the time of the incident, with neurologist Kareti noting brain irritative processes that could cause seizures.
Amerson filed § 1983 claims for excessive force and for Waterford Township’s failure-to-train and failure-to-supervise; district court granted summary judgment against him, except denying none for Mahoney, and later granted summary judgment for Waterford on the remaining claims.
The Sixth Circuit reversed in part: held Stechly’s excessive-force claim should survive; affirmed the rest and remanded for proceedings on that claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stechly used excessive force under the Fourth Amendment	Amerson asserts Stechly punched/kicked him while restrained on the ground.	Defendants contend the record belies Amerson’s version and shows no excessive force.	Amerson’s claim against Stechly survives; district court erred in granting summary judgment.
Whether Mahoney can be liable for excessive force by failing to intervene	Mahoney had a duty to intervene once he observed or could have observed excessive force.	Mahoney had no notice, opportunity, or means to intercede in the brief, seconds-long incident.	No intervention duty; summary judgment affirmed for Mahoney.
Whether Waterford Township can be liable for failure to train under Monell	Waterford failed to train officers on use of force, intervention, and updated policies.	Plaintiff did not show deliberate indifference or causal link between training and injury.	District court correct; no deliberate indifference shown; failure-to-train affirmed.
Whether Waterford Township can be liable for failure to supervise under Monell	Lack of supervision/monitoring allowed excessive force to go unchecked.	Evidence does not show deliberate indifference or a moving force behind injury.	No failure-to-supervise liability; district court affirmed.

Graham v. Connor, 490 U.S. 386 (U.S. 1989) (excessive-force standard in arrests and detentions)
Scott v. Harris, 550 U.S. 372 (U.S. 2007) (blatantly contradictory evidence on summary judgment)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (credibility and weighing evidence at summary judgment)
City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (deliberate indifference standard for failure-to-train)
Turner v. Scott, 119 F.3d 425 (6th Cir. 1997) (requirements to hold an officer liable for failing to intervene)
Ontha v. Rutherford County, 222 F. App’x 498 (6th Cir. 2007) (brief time frame limits intervention liability)
Mayo v. Macomb Cnty., 183 F.3d 554 (6th Cir. 1999) (insufficiency of training cannot be inferred from injury avoidance alone)
Monell v. Dep’t of Soc. Servs. of the City of New York, 436 U.S. 658 (U.S. 1978) (municipal liability requires official policy or custom)
Harris v. Miller; Miller v. Calhoun County, 408 F.3d 803 (6th Cir. 2005) (deliberate indifference framework for training claims)
Dodson, 454 U.S. 312 (U.S. 1981) (moving force behind constitutional violations in Monell claims)