Kathleen Meehan v. Officer Scott Thompson
2014 U.S. App. LEXIS 15601
| 8th Cir. | 2014Background
- On April 28, 2011 Meehan was a passenger in a car driven by an intoxicated friend; police at the scene arrested the driver and placed Meehan under officer supervision after officers believed she was also intoxicated.
- Officer Thompson ordered Meehan out of the car, frisked her, placed her in his squad car, denied her requests to go to a nearby store or call a taxi, and transported her ~10 miles to a detox facility. Her BAC later tested at .082.
- Meehan sued under 42 U.S.C. § 1983 for Fourth Amendment violations (unreasonable seizure/arrest and an unlawful frisk/excessive force) and asserted state-law battery and false imprisonment claims.
- Thompson moved for summary judgment asserting qualified immunity (federal claims) and official immunity (state claims); the district court denied the motion.
- The Eighth Circuit reversed: it held that the law was not clearly established that Thompson’s conduct violated the Fourth Amendment and that he was entitled to official immunity under Minnesota law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of arrest/transport as a seizure (community-caretaker) | Meehan: arrest/transport unreasonable because her intoxication was mild and she posed no danger | Thompson: reasonably believed Meehan was moderately intoxicated and potentially endangered standing alone at night; community-caretaker seizure justified | Reversed — law not clearly established that arresting a moderately intoxicated person under these facts violated the Fourth Amendment; qualified immunity applies |
| Frisk/search legality (Terry justification) | Meehan: frisk lacked reasonable suspicion of being armed/dangerous | Thompson: frisk was incident to an arrest for safety; search incident to arrest requires no separate Terry justification | Reversed — because arrest was at least arguably lawful, search-incident-to-arrest doctrine applies |
| Excessive force for the frisk | Meehan: frisk was violent and violative, even if injuries were minor | Thompson: only de minimis injury resulted; at the time it was not clearly established that de minimis injury could support a Fourth Amendment excessive-force claim | Reversed — Chambers (recognizing de minimis injury claims) postdated the incident; qualified immunity applies |
| State-law battery / false imprisonment (official immunity) | Meehan: Thompson acted without justification and should not get immunity | Thompson: acted within discretion; no evidence he acted maliciously or willfully | Reversed — no specific evidence of malice; official immunity applies; state claims dismissed |
Key Cases Cited
- Cady v. Dombrowski, 413 U.S. 433 (recognition of police community-caretaker function)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
- Anderson v. Creighton, 483 U.S. 635 (clearly established right standard)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity analytical framework)
- United States v. Robinson, 414 U.S. 218 (search incident to a lawful arrest needs no additional justification)
- Wilkins v. Gaddy, 559 U.S. 34 (excessive force and injury discussion)
- Chambers v. Pennycook, 641 F.3d 898 (Eighth Circuit recognizing de minimis-injury excessive-force claims)
- Winters v. Adams, 254 F.3d 758 (Eighth Circuit upholding caretaker seizures of apparently intoxicated individuals)
- United States v. Rideau, 969 F.2d 1572 (Fifth Circuit upholding removal of intoxicated person from public for safety)