Melinda Williams v. Mark Papi
714 F. App'x 128
3rd Cir.2017Background
- Brian Williams was subject to an involuntary commitment warrant; police from multiple municipalities responded after he barricaded himself in his home and basement.
- Officers entered the house using a key from Mrs. Williams, forced open a bedroom door, and found Williams holding a fireplace poker.
- Three officers deployed Tasers without effect; Officer Papi shot and killed Williams after a disputed surge/movement with the poker.
- Mrs. Williams sued under 42 U.S.C. § 1983 for excessive force (entry and lethal force) and asserted supervisory-liability claims against several chiefs and a corporal.
- District Court denied summary judgment to both sides, finding genuine factual disputes about whether Williams posed an imminent threat and about officers’ perceptions and conduct.
- On appeal, defendants argued they accepted the District Court’s disputed facts and sought qualified immunity as a matter of law; the Third Circuit found it lacked jurisdiction to resolve most qualified-immunity issues because material factual disputes remained but reached and decided certain supervisory-liability questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether appellate review permitted on denial of qualified immunity for alleged excessive force (entry and shooting) | Williams: facts support constitutional violations; denial of summary judgment was proper | Defendants: accept district-court factual findings and argue entitlement to qualified immunity as a legal matter | Court: Lacked jurisdiction to decide qualified immunity for these claims because resolution requires reviewing disputed, fact-bound determinations (Johnson v. Jones) |
| Whether appellate court may treat disputed factual findings as accepted and decide qualified immunity as pure legal question | Williams: disputed facts control and preclude pure legal review | Defendants: propose accepting district court’s facts for appeal and then arguing objective reasonableness | Court: While theoretically possible, here defendants did not genuinely accept all material findings (central factual disputes remained), so appellate jurisdiction is lacking |
| Whether supervisors (Chiefs Fisher, Kreig, Ely, Olszewski; Corporal Miller) are liable under supervisory-liability theories | Williams: supervisors participated, directed, or acquiesced; thus liable | Defendants: challenge sufficiency of personal involvement and entitlement to qualified immunity | Court: Has jurisdiction only over pure-law supervisory-liability issues; reversed district court as to Fisher and Krieg (Fisher entitled to qualified immunity; Krieg cannot be held liable as a supervisor for subordinates he had none of) but dismissed for lack of jurisdiction as to Ely, Olszewski, Miller |
| Whether failure-to-appear/off-duty supervisor liability is clearly established | Williams: Fisher’s off-duty failure to appear left an unprepared subordinate and supports liability | Fisher: off-duty knowledge without direction insufficient for liability | Held: Not clearly established that off-duty failure to appear creates supervisory liability; Fisher entitled to qualified immunity |
Key Cases Cited
- Mitchell v. Forsyth, 472 U.S. 511 (recognizes collateral-order appealability of denial of qualified immunity when it presents an issue of law)
- Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541 (foundational collateral-order doctrine)
- Johnson v. Jones, 515 U.S. 304 (denial of qualified immunity not immediately appealable when resolution requires fact determinations)
- Behrens v. Pelletier, 516 U.S. 299 (clarifies when qualified-immunity orders are appealable)
- Ashcroft v. al-Kidd, 563 U.S. 731 (qualified immunity and clearly-established-law standard)
- County of Los Angeles v. Mendez, 137 S. Ct. 1539 (reasonableness analysis must address each alleged seizure separately)
- White v. Pauly, 137 S. Ct. 548 (consider only facts knowable to the defendant officers)
- Pearson v. Callahan, 555 U.S. 223 (courts may grant qualified immunity on the clearly-established step alone)
- Santini v. Fuentes, 795 F.3d 410 (Third Circuit two-step qualified-immunity framing)
- Argueta v. U.S. Immigration & Customs Enf’t, 643 F.3d 60 (personal involvement required for supervisory liability)
- A.M. ex rel. J.M.K. v. Luzerne Cty. Juvenile Det. Ctr., 372 F.3d 572 (means to establish supervisor personal involvement)
- Santiago v. Warminster Twp., 629 F.3d 121 (discusses viability of knowledge-and-acquiescence supervisory theory post-Iqbal)
- Reedy v. Evanson, 615 F.3d 197 (supervisor kept abreast of events but not liable without direction or specific awareness)