Matthew Parrish v. Jason Dingman, 912 F.3d 464

Parrish was arrested at a checkpoint, booked into Hamilton County Jail, and told jailer Jason Dingman about prior serious injuries (broken femur/arm, limp, double vision, orthotic shoe); Dingman allowed Parrish to keep shoes and glasses and gave him a mattress.
Parrish asked for an isolated cell; Dingman refused. While carrying the mattress into a holding cell, Parrish stepped toward an open cell door with the mattress protruding through the door.
Dingman perceived Parrish’s movement and the mattress as a threat and possible escape attempt; he entered the cell, pushed Parrish into the wall, forced him to the floor using arm/neck control, and handcuffed him.
Parrish sustained wrist swelling/bruising, rib and back injuries, and sought mental health treatment; he sued Dingman, Sheriff Hagenson, and Hamilton County under 42 U.S.C. § 1983 and Iowa law for excessive force and assault/battery.
The district court granted summary judgment and qualified immunity to defendants; the Eighth Circuit reviewed de novo and affirmed dismissal of federal and state claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dingman used excessive force in violation of the Fourth Amendment	Parrish: he was cooperative, unarmed, disabled; force was unnecessary	Dingman: reasonable belief Parrish was attempting to leave and posed a threat; force was proportional	No constitutional violation; force objectively reasonable; qualified immunity applies
Whether force amount was excessive given injuries and disabilities	Parrish: injuries and known disabilities made force disproportionate	Dingman: split-second judgment justified; technique was a common restraint and proportional	Use of force was proportional and reasonable under the circumstances
Whether county is liable under respondeat superior for assault/battery	Parrish: county liable for employee’s wrongful acts	County: no employee liability because force was lawful and reasonable	No municipal liability because employee did not commit actionable wrongdoing
Whether Iowa law permits the force used to prevent escape/arrest	Parrish: statutory protections and disabilities limit force	Defendants: Iowa statutes allow reasonable force to prevent escape and effect arrest	Iowa law authorizes the force used when objectively reasonable; summary judgment affirmed

Ashcroft v. al-Kidd, 563 U.S. 731 (qualified immunity standard)
Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
Graham v. Connor, 490 U.S. 386 (objective-reasonableness test for use of force)
Kingsley v. Hendrickson, 576 U.S. 389 (deference to jail security and institutional interests)
Shekleton v. Eichenberger, 677 F.3d 361 (force against disabled person; distinguishable facts)
Hicks v. Norwood, 640 F.3d 839 (Fourth Amendment reasonableness for booking process)
Blazek v. City of Iowa City, 761 F.3d 920 (common, non-excessive restraint technique)