Matthew Reid Hinson v. R.A. Bias, 927 F.3d 1103

On Oct. 6, 2012, Matthew Hinson stabbed an unknown man to death at a pub; Hinson left and was arrested at a parking-garage checkout booth shortly thereafter.
Surveillance video (no audio) and officers’ sworn statements are the only contemporaneous accounts of the arrest; Hinson professed no memory of events after raising his hands in the truck.
Officers approached with guns drawn; Hinson initially delayed complying, dropped a knife out the window, exited the truck, was taken to the ground, and was struck several times (five strikes by Bias, one by Anderson) before being handcuffed; minor facial abrasions resulted.
Jail medical screening documented only minor, non-bleeding abrasions; a forensic pathologist concluded the injuries were superficial and did not require medical attention.
Hinson sued under 42 U.S.C. § 1983 for Fourth Amendment excessive force and Eighth Amendment deliberate indifference to medical needs; district court denied most defendants qualified immunity on summary judgment; officers appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force (Fourth Amendment)	Officers "slammed" Hinson, repeatedly beat him with flashlights, and kicked him while handcuffed and prone	Force was objectively reasonable given a recent murder, Hinson’s noncompliance and potential access to weapons; strikes were limited and aimed to secure compliance	Officers entitled to qualified immunity; force was reasonable under Graham factors
Failure-to-intervene	Non-participating officers failed to stop excessive force	Non-participating officers observed no unlawful force and were not in a position to prevent it	Entitled to qualified immunity because no underlying Fourth Amendment violation was shown
Deliberate indifference to medical needs (Eighth Amendment)	Officers ignored bleeding/wounds and denied timely medical care, causing lasting injuries (ear problems, migraines)	Injuries were minor abrasions, not an objectively serious medical need; Hinson never requested treatment; no causal link to claimed chronic conditions	Entitled to qualified immunity; Hinson failed to show a serious medical need or causation
Qualified immunity standard / burden	N/A — plaintiff contends violations were clearly established	Officers acted within discretionary authority; plaintiff must show constitutional violation and clearly established law	Officers acted within discretionary authority and satisfied immunity because no constitutional violations were established

Pearson v. Callahan, 555 U.S. 223 (Sup. Ct. 2009) (qualified-immunity framework; courts may decide order of inquiry)
Harlow v. Fitzgerald, 457 U.S. 800 (Sup. Ct. 1982) (officials protected unless they knew or reasonably should have known they were violating clearly established rights)
Graham v. Connor, 490 U.S. 386 (Sup. Ct. 1989) (objective-reasonableness standard for excessive-force claims)
Anderson v. Liberty Lobby, 477 U.S. 242 (Sup. Ct. 1986) (summary-judgment standard; mere scintilla insufficient)
Scott v. Harris, 550 U.S. 372 (Sup. Ct. 2007) (video evidence can refute a nonmoving party’s version of events)
Estelle v. Gamble, 429 U.S. 97 (Sup. Ct. 1976) (deliberate indifference to medical need violates the Eighth Amendment)
Crenshaw v. Lister, 556 F.3d 1283 (11th Cir. 2009) (liability for failure to intervene)
Mobley v. Palm Beach Cty. Sheriff's Dep't, 783 F.3d 1347 (11th Cir. 2015) (analysis of force proportionality and injury significance)
Stephens v. DeGiovanni, 852 F.3d 1298 (11th Cir. 2017) (force must be reasonably proportionate to need)
Beshers v. Harrison, 495 F.3d 1260 (11th Cir. 2007) (video can contradict plaintiff’s account and defeat summary judgment opposition)