Lamar Wright v. City of Euclid
962 F.3d 852
| 6th Cir. | 2020Background
- Plainclothes Euclid officers Kyle Flagg and Vashon Williams, in an unmarked car, approached Lamar Wright’s parked SUV with guns drawn; Wright reversed when he thought he was being robbed, then complied once he saw a badge.
- After holstering, officers opened the driver’s door, struggled to remove Wright (who had recent abdominal surgery, staples, and a colostomy bag), and then simultaneously tased (Flagg) and pepper-sprayed (Williams) him while he was still seated; the staples were aggravated and he bled.
- Officers arrested Wright for misdemeanors (resisting, obstructing, trespass, turn-signal), designated the stop as drug-related despite no drugs, and he was detained after posting bond for several additional hours for a county body scan; all charges were later dropped.
- District court granted summary judgment for the officers (qualified immunity) and the City (Monell). Wright appealed several § 1983 and Ohio-law claims.
- Sixth Circuit: reversed summary judgment on excessive force (tasing/pepper spray/brandishing), false arrest, extended detention, and federal malicious prosecution; affirmed dismissal of failure-to-intervene and IIED; reinstated Monell theories (training, ratification, custom) based on training materials and practices (including a Chris Rock video link and an offensive cartoon).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force — firearms drawn | Wright: officers unreasonably brandished guns when he posed no threat | Officers: reasonable given suspected drug activity and officer safety | Jury question; qualified immunity denied for brandishing (facts disputed) |
| Excessive force — taser & pepper spray | Wright: tasing and close-range pepper spray while non‑resisting was excessive | Officers: Wright resisted and posed safety risk | Jury question; qualified immunity denied for both uses (facts viewed in plaintiff’s favor) |
| Failure to intervene | Wright: each officer could and should have stopped the other | Officers: each was occupied/ unaware and lacked opportunity to intercede | Affirmed for defendants — no reasonable opportunity to intervene |
| False arrest & extended detention | Wright: no probable cause for arrest or subsequent drug-designation detention | Officers: probable cause based on resisting/obstruction and investigatory needs | Reversed — jury could find lack of probable cause; extended detention actionable |
| Federal malicious prosecution | Wright: officers influenced prosecution and recklessly misrepresented drug aspect | Officers: charges were supported by their reports | Reversed — material disputes; jury could find reckless falsehoods leading to prosecution |
| Monell (municipal liability) | Wright: training materials, lack of meaningful training committee, and ratification show custom/failure to train/ratification | City: no policy caused constitutional violation; training adequate | Reversed — sufficient evidence (Chris Rock video, cartoon, poor training/supervision) to send Monell claims to jury |
| Ohio statutory immunity & state malicious prosecution | Wright: officers’ conduct was wanton/reckless and malice can be inferred from lack of probable cause | Officers/City: entitled to immunity under Ohio Rev. Code ch. 2744 | Reversed as to state malicious prosecution (malice inference); statutory immunity denied where facts overlap with federal analysis |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (objective-reasonableness test for use of force)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability requires policy or custom)
- City of Canton v. Harris, 489 U.S. 378 (failure-to-train standard)
- Ashcroft v. al-Kidd, 563 U.S. 731 (qualified immunity: no ruling at high level of generality)
- Hope v. Pelzer, 536 U.S. 730 (preexisting law can make unlawfulness apparent)
- Brown v. Chapman, 814 F.3d 447 (6th Cir.) (tasering non‑resisting suspect can be excessive force)
- Coffey v. Carroll, 933 F.3d 577 (6th Cir.) (drawing line at active resistance for force analysis)
- Binay v. Bettendorf, 601 F.3d 640 (6th Cir.) (pointing a gun can be excessive force)
- Jackson v. City of Cleveland, 925 F.3d 793 (6th Cir.) (Monell proof methods and training assessment)
- Jones v. City of Elyria, 947 F.3d 905 (6th Cir.) (false narrative reports can support malicious-prosecution/Monell inferences)