Lombardo v. St. Louis, 594 U.S. 464

Dec. 8, 2015: Police arrested Nicholas Gilbert; officers observed him attempt to hang himself in a holding cell, intervened, and a physical struggle ensued.
Officers handcuffed Gilbert behind his back, applied leg shackles, moved him to a prone position, and at least one officer applied pressure to his back/torso while several officers held his limbs for about 15 minutes.
Gilbert’s breathing became abnormal, he lost consciousness, was transported to a hospital, and was pronounced dead.
Plaintiffs (Gilbert’s parents) sued for excessive force. The District Court granted summary judgment to the officers on qualified immunity grounds; the Eighth Circuit affirmed on the merits, holding force was not unconstitutional.
The Supreme Court granted certiorari, vacated the Eighth Circuit’s judgment, and remanded—finding it unclear whether the court performed the required, context-specific Kingsley/Graham analysis (and noting record evidence about pressure on the back and departmental guidance discouraging prone pressure).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers used constitutionally excessive force in restraining Gilbert.	Force was unreasonable: Gilbert was handcuffed and shackled, officers pressed on his back for ~15 minutes contrary to training, and the restraint caused or contributed to death.	Use of prone restraint was reasonable to prevent self-harm because Gilbert actively resisted; prior circuit precedent supports restraint of resisting detainees.	Supreme Court did not decide merits; vacated and remanded for the court of appeals to apply a careful, context-specific Kingsley/Graham analysis.
Whether the Eighth Circuit applied the proper excessive-force test (Kingsley/Graham) or treated prone restraint as per se reasonable when a detainee resists.	Eighth Circuit minimized facts (duration, restraints, pressure on back) that Kingsley requires courts to weigh.	Eighth Circuit applied precedent (Ryan) and considered the factual differences insignificant under the totality of circumstances.	Supreme Court found it unclear whether the court applied the required fact-sensitive inquiry and remanded for clarification.
Whether Gilbert’s right was clearly established (qualified immunity).	Plaintiffs argued the right to be free from such force was clearly established.	Officers asserted qualified immunity/that law was not clearly established.	Supreme Court expressly declined to resolve qualified-immunity / clearly-established question and left it to the court of appeals on remand.

Tolan v. Cotton, 572 U.S. 650 (per curiam) (on summary-judgment standard: view evidence in light most favorable to nonmovant)
Graham v. Connor, 490 U.S. 386 (excessive-force claim judged by objective-reasonableness standard)
Kingsley v. Hendrickson, 576 U.S. 389 (context-specific factors for evaluating force against detainees)
Ryan v. Armstrong, 850 F.3d 419 (8th Cir.) (prior circuit decision addressing prone restraint and resistance under totality of circumstances)
Lombardo v. Saint Louis City, 361 F. Supp. 3d 882 (E.D. Mo. 2019) (district-court decision granting qualified immunity at summary judgment)
Lombardo v. City of St. Louis, 956 F.3d 1009 (8th Cir.) (court of appeals decision affirming no constitutional violation)
United States v. Pope, 910 F.3d 413 (8th Cir. 2018) (noting handcuffs limit but do not eliminate ability to cause harm)