Mary Jo. Bradley v. Officer Casey Benton, 10 F.4th 1232

Officer Casey Benton stopped a white SUV leaving an apartment complex after observing an unusual temporary tag; he ran the tag in the system but did not recall the result and did not issue a citation.
Driver Wilford Sims told officers he had a handgun; Benton removed a loaded gun from the center console; Troy Robinson was a passenger and had no ID.
When officers tried to run Robinson’s name, Robinson fled on foot across a busy road, through a Family Dollar parking lot, over a chain-link fence, and attempted to climb an eight-foot concrete wall bordering the apartment complex.
Benton pursued on foot and fired a single taser deployment; plaintiffs’ evidence (eyewitness testimony and a taser blast door found on the far side of the wall) supports a version in which Benton tased Robinson while Robinson was atop the wall, causing incapacitation, a fall, and fatal blunt force trauma to head/neck.
Benton testified the taser was fired while Robinson was on the ground and was ineffective (only one probe made contact); Benton conceded department training that tasers can incapacitate and should not be used when a fall could be fatal (e.g., elevated heights).
The district court granted official immunity on state claims but denied qualified immunity on the §1983 excessive-force claim; the Eleventh Circuit affirmed denial as to the tasing (clearly established excessive force) and reversed as to the lawfulness of the stop and the pursuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Lawfulness of initial traffic stop (reasonable suspicion)	Stop was pretextual and lacked reasonable, particularized suspicion.	Tag looked improper (no visible expiration date); stop was objectively justified.	Stop was lawful; Benton had reasonable suspicion to stop the vehicle.
Lawfulness of pursuit after Robinson fled	Pursuit was unlawful because stop was unlawful and passenger not subject to seizure absent more.	Headlong flight justified pursuit; behavior was suspicious enough to continue detention efforts.	Pursuit was lawful: flight afforded reasonable suspicion to chase Robinson.
Use of force (tasing atop an elevated wall) / qualified immunity	Tasing an unarmed, nonviolent suspect atop an eight-foot wall was deadly/excessive force and violated clearly established Fourth Amendment rights.	Taser deployment was reasonable (or ineffective) and the law was not clearly established for this factual context.	Tasing at elevated height violated clearly established law; qualified immunity denied as to tasing; claim proceeds to trial.

Tennessee v. Garner, 471 U.S. 1 (U.S. 1985) (deadly force to prevent escape from fleeing, unarmed suspect violates Fourth Amendment)
Graham v. Connor, 490 U.S. 386 (U.S. 1989) (objective reasonableness standard for use of force)
Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (headlong flight as relevant to reasonable suspicion)
Whren v. United States, 517 U.S. 806 (U.S. 1996) (subjective intent of officer irrelevant to Fourth Amendment stop if objective basis exists)
Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (qualified immunity two-step framework; courts may decide order of prongs)
Mullenix v. Luna, 577 U.S. 7 (U.S. 2015) (need for especially analogous precedent in Fourth Amendment qualified-immunity cases)
McCullough v. Antolini, 559 F.3d 1201 (11th Cir. 2009) (factors for evaluating deadly-force reasonableness)
Cantu v. City of Dothan, 974 F.3d 1217 (11th Cir. 2020) (requirements for deadly-force use and warning feasibility)
Fils v. City of Aventura, 647 F.3d 1272 (11th Cir. 2011) (taser generally not a deadly weapon but can be depending on use)
Pruitt v. City of Montgomery, 771 F.2d 1475 (11th Cir. 1985) (definition of force that creates substantial risk of death or serious bodily harm)