Matthew King v. Hendricks County Commissioner, 954 F.3d 981

Bradley King, a 29‑year‑old with diagnosed paranoid schizophrenia, called 9‑1‑1 for help; two Hendricks County reserve deputies (Jason Hays and Jeremy Thomas) conducted a welfare check.
Deputies testified Bradley exited the home with a 10‑inch kitchen knife in his left hand, ignored commands to drop it, charged Hays from about eight feet, and Hays fired one fatal shot; the knife was recovered near Bradley’s left hand and autopsy wounds/trajectory were consistent with officers’ account.
Bradley’s father disputes the officers’ account, arguing Bradley was nonviolent, likely right‑handed (so wouldn’t hold the knife left), the knife bore no usable prints, and the trajectory suggests a different positioning—arguing the knife was planted and the shooting unjustified.
Plaintiff sued under 42 U.S.C. § 1983 (excessive force), Title II of the ADA and the Rehabilitation Act (deliberate indifference/discrimination), and state claims; the district court granted summary judgment to defendants on federal claims and declined supplemental jurisdiction over state claims.
The Seventh Circuit reviewed de novo and affirmed: it held no genuine dispute of material fact supported a Fourth Amendment violation or Title II/Rehab Act liability, and therefore municipal liability could not attach.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourth Amendment excessive‑deadly force (Hays)	King: Bradley did not pose an immediate threat; officers fabricated/ planted knife.	Hays: Deputies’ testimony, knife location, wound/trajectory support that Bradley charged with a large knife, justifying lethal force.	Summary judgment for Hays; plaintiff’s evidence is speculative and does not create a genuine fact issue.
Municipal (Monell) liability against county/sheriff	County failed to train/ supervise re: mental‑illness encounters; deliberate indifference caused deprivation.	Municipal Defs: No underlying constitutional violation by Hays; training criticism insufficient without constitutional injury.	Summary judgment for municipal defendants; no Monell liability because no proven Fourth Amendment violation.
ADA / Rehabilitation Act (Title II)	Disability discrimination/deliberate indifference—county failed to accommodate Bradley’s mental illness, causing his death.	Defs: Even assuming Title II applies, Bradley’s disability was not the but‑for cause; officer would have acted the same to a non‑disabled person who charged with a knife.	Summary judgment for defendants; no evidence that disability, rather than violent conduct, caused the deprivation.
Qualified immunity (Hays)	King: conduct unconstitutional.	Hays: asserted qualified immunity as alternative defense.	Court did not address qualified immunity after resolving the claim on the merits against King.

Tennessee v. Garner, 471 U.S. 1 (1985) (deadly force constitutes a "seizure" and is permissible only when officer has probable cause to believe subject poses immediate threat)
Graham v. Connor, 490 U.S. 386 (1989) (objective‑reasonableness standard for use of force; judge from officer's on‑scene perspective)
Kisela v. Hughes, 138 S. Ct. 1148 (2018) (deference to split‑second police judgments about force)
City & County of San Francisco v. Sheehan, 575 U.S. 600 (2015) (officer decisionmaking in tense, rapidly evolving situations and limits of hindsight critique)
Monell v. New York City Dep’t of Social Servs., 436 U.S. 658 (1978) (municipal liability requires a constitutional violation by agent or an official policy causing the violation)
Gray v. Cummings, 917 F.3d 1 (1st Cir. 2019) (mental illness is a factor in assessing reasonableness of force; Title II may apply to police encounters)
Sanzone v. Gray, 884 F.3d 736 (7th Cir. 2018) (deadly force reasonable where officer has probable cause to believe immediate threat exists)
Plakas v. Drinski, 19 F.3d 1143 (7th Cir. 1994) (availability of less‑lethal alternatives does not necessarily render deadly force unreasonable)