Lanier v. Wycoff, 1:22-cv-00120

Plaintiff Ricardo Lanier, a pretrial detainee at Henderson County Detention Center, sued under 42 U.S.C. § 1983 alleging excessive force by Deputy Caleb Wycoff and failure to intervene by Detention Officer Antonio Soriano; a third defendant was dismissed for lack of service.
Incident (Jan. 11, 2022): during meal-tray collection Lanier left his cell and sat on a table to get an officer’s attention; Wycoff, Soriano, and Edwards approached to order him back to his cell.
Video footage shows an exchange in which Wycoff reached with an open hand, Lanier reacted by swinging, jumping off the table, assuming an aggressive stance, and resisted officers; Wycoff deployed a taser twice to subdue him.
Lanier was criminally charged, entered Alford pleas to assaulting detention staff, and received a 10–21 month sentence; video and photographs documented officers’ injuries and minimal visible injuries to Lanier.
Defendants moved for summary judgment; they stipulated to dismiss counterclaims if summary judgment were granted. The court struck an unauthorized surreply and considered video evidence in granting summary judgment.
Court granted summary judgment for defendants, concluding (1) force used was objectively reasonable under the Fourteenth Amendment and (2) defendants entitled to qualified immunity; the action was dismissed with prejudice as frivolous and malicious and counterclaims dismissed per stipulation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force (pretrial detainee)	Lanier contends Wycoff threatened and struck with a closed fist and then tased him gratuitously while immobile	Wycoff and Soriano argue Lanier acted violently, resisted, and taser use was necessary and proportionate	Court held force was objectively reasonable; summary judgment for defendants
Failure to intervene	Lanier says Soriano aided or failed to stop Wycoff’s alleged gratuitous force	Soriano asserts he attempted to control Lanier and did not fail to intervene; video shows joint response to resistance	Court held no bystander liability; summary judgment for defendants
Qualified immunity	N/A — Lanier argues constitutional violation	Defendants say even if force occurred, their conduct was reasonable and not a clearly established violation	Court ruled defendants entitled to qualified immunity because no constitutional violation was shown
Evidentiary sufficiency at summary judgment	Lanier relied on verified complaint allegations and a surreply	Defendants relied on declarations, video, and photos showing contrary facts	Court found Lanier’s account blatantly contradicted by video; no genuine dispute of material fact

Kingsley v. Hendrickson, 576 U.S. 389 (2015) (pretrial detainee excessive-force standard is objective unreasonableness)
Graham v. Connor, 490 U.S. 386 (1989) (force claims evaluated under reasonableness principles)
Randall v. Prince George’s Cnty., 302 F.3d 188 (4th Cir. 2002) (elements for bystander failure-to-intervene liability)
Stevenson v. City of Seat Pleasant, Md., 743 F.3d 411 (4th Cir. 2014) (recognizing bystander liability theory in Fourth Circuit)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (movant’s initial summary judgment burden and evidence sources)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (genuine dispute and jury standard at summary judgment)
Scott v. Harris, 550 U.S. 372 (2007) (court may disregard a party’s version blatantly contradicted by video evidence)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (nonmoving party must do more than create metaphysical doubt to defeat summary judgment)