Marcus Blazek v. Juan Santiago
761 F.3d 920
| 8th Cir. | 2014Background
- Blazek was a non-parolee roommate of a parolee (Feldhacker) whose residence was subject to warrantless parole searches; parole officer Santiago went to the apartment after a failed drug test.
- Santiago knocked, claims someone looked through the peephole and fled while a toilet flushed; backup Officer Roth and the apartment manager entered; Santiago encountered Blazek emerging from the bathroom in a towel.
- Officers detained Blazek for investigation; Blazek was belligerent, refused to identify himself beyond “the roommate,” and would not stay seated.
- Blazek alleges a sequence of force: Santiago grabbed and twisted his arm, threw him to the floor, Roth jumped on and handcuffed him, then both officers jerked him from the floor onto the bed.
- Blazek later sought medical care: diagnosed with separated shoulder, ankle fracture, and later a torn rotator cuff; he sued under § 1983 (Fourth Amendment excessive force and seizure) and state-law claims.
- District court denied officers’ qualified-immunity summary-judgment motions; the Eighth Circuit affirms denial in part (no immunity for the alleged jerking from the floor onto the bed) but grants immunity for the handcuffing maneuver itself. Court lacks jurisdiction to resolve Roth’s appeal as to state-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers used excessive force in handcuffing Blazek | Handcuffing involved twisting, throwing, and jumping on Blazek and caused serious injuries (shoulder, rotator cuff, ankle) — unconstitutional | Similar handcuffing takedowns have been held reasonable; officers acted reasonably under prevailing circuit precedent | Qualified immunity granted for the handcuffing maneuver (officers entitled to immunity) |
| Whether officers used excessive force when jerking Blazek from floor to bed (after handcuffed) | Jerking a subdued, handcuffed detainee was gratuitous, unnecessary, and caused serious injury — violates Fourth Amendment | Officers could lawfully lift or roughly pull a handcuffed detainee; not all rough handling is excessive | Qualified immunity denied for the jerking-up claim (genuine issue for jury) |
| Whether the officers’ conduct violated a clearly established right in 2009 | Preexisting decisions (e.g., Kukla, Henderson) put officers on notice that unnecessary violence against subdued detainees is unlawful | Courts have allowed similar takedown/handcuffing techniques; law not "beyond debate" — officers could reasonably believe conduct lawful | For handcuffing: right not clearly established in 2009 (immunity). For jerking: right was clearly established (no immunity) |
| Jurisdiction over state-law claims on interlocutory appeal | — (Blazek did not appeal here) | Roth appealed denial of summary judgment on state-law claims | Court held it lacked jurisdiction to entertain Roth’s interlocutory appeal as to state-law claims |
Key Cases Cited
- Mitchell v. Forsyth, 472 U.S. 511 (qualified immunity interlocutory appeal under collateral-order doctrine)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-prong framework)
- Ashcroft v. al-Kidd, 563 U.S. 731 (need for clearly established law; "beyond debate")
- Saucier v. Katz, 533 U.S. 194 (analysis of excessive force on "hazy border")
- Wertish v. Krueger, 433 F.3d 1062 (8th Cir.) (handcuffing/takedown treated as reasonable in earlier case)
- Kukla v. Hulm, 310 F.3d 1046 (8th Cir.) (denial of immunity where force during handcuffing caused serious injury)
- Henderson v. Munn, 439 F.3d 497 (8th Cir.) (gratuitous violence against subdued detainee unreasonable)
- Chambers v. Pennycook, 641 F.3d 898 (8th Cir.) (handcuffing may cause minor injury; degree of injury relevant to force analysis)
- Copeland v. Locke, 613 F.3d 875 (8th Cir.) (sequence of force during arrest can support Fourth Amendment claim)