Michael Cantrell v. City of Murphy, 2012 U.S. App. LEXIS 63

Cantrells sue the City of Murphy, ETMC, and several officers under 42 U.S.C. § 1983 for constitutional violations and state-law negligence arising from events of October 2, 2007.
District court dismissed some claims but denied qualified immunity on two Cantrell claims against Officer Defendants.
On October 2, 2007, Ave Cantrell called 911 after her son Matthew became entangled in a soccer net; responders learned Matthew was not breathing and was in distress.
Officers separated Matthew from his mother, began crime-scene procedures, and detained Ave at the police station while the scene was processed.
Cantrells alleged a ‘special relationship’ under the Due Process Clause created by the officers’ custodial actions and delay in aid; they also claimed Fourth Amendment violations related to Ave’s detention.
The district court found some claims viable (including Monell issues) but the appellate court reverses, holding officers are entitled to qualified immunity on the asserted claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the special-relationship theory defeats qualified immunity.	Cantrells	Officers	Officers entitled to qualified immunity; no clearly established duty.
Whether the Fourth Amendment detention of Ave violated rights under clearly established law.	Cantrells	Officers	Officers had probable cause to detain Ave; no Fourth Amendment violation.

Saucier v. Katz, 533 U.S. 194 (Supreme Court, 2001) (two-step qualified-immunity framework (initially mandatory))
Pearson v. Callahan, 555 U.S. 223 (Supreme Court, 2009) (two-step inquiry may be undertaken in any order)
DeShaney v. Winnebago Cnty. Dep’t of Social Servs., 489 U.S. 189 (Supreme Court, 1989) (special-relationship exception to general no-duty rule)
Estelle v. Gamble, 429 U.S. 97 (Supreme Court, 1976) (state must provide care when custody imposes responsibility)
Youngberg v. Romeo, 457 U.S. 307 (Supreme Court, 1982) (custody imposes special duties for safety and well-being)
Anderson v. Creighton, 483 U.S. 635 (Supreme Court, 1987) (clearly established inquiry requires specific, not abstract, rights)
Kinney v. Weaver, 367 F.3d 337 (Fifth Cir. 2004) (framework for analyzing qualified immunity in § 1983 cases)
Wernecke v. Garcia, 591 F.3d 386 (Fifth Cir. 2009) (clearly established, general vs. specific rights in qualified immunity)
Freeman v. Gore, 483 F.3d 404 (Fifth Cir. 2007) (standard for analyzing whether conduct was objectively unreasonable)
Brown v. Miller, 519 F.3d 231 (Fifth Cir. 2008) (notice standard for clearly established rights in qualified immunity)
Maag v. Wessler, 960 F.2d 773 (9th Cir. 1991) (probable-cause concepts in detention of mentally ill individuals)