Michael McReynolds v. Darrell Schmidli, 4 F.4th 648

Early morning 2012: 911 call reporting a domestic disturbance; Officers Darrell Schmidli and Derek Gentile responded and encountered Michael McReynolds outside the residence.
Officers ordered McReynolds to the ground; he stopped, dropped to his knees and raised his hands; after being asked to get on his stomach and requesting clarification, Schmidli tackled him from behind, driving his face into the pavement and fracturing his jaw.
McReynolds was treated at a hospital, booked for domestic violence and interfering with police, convicted at a bench trial on the interfering charge, and later acquitted at a de novo jury trial under Missouri law.
McReynolds sued under 42 U.S.C. § 1983 for excessive force (Schmidli, Gentile), for falsely charging/reporting/testifying (officers), and asserted a Monell claim against the City of Independence.
The district court granted summary judgment for defendants: it found a constitutional violation by Schmidli but awarded him qualified immunity, granted qualified immunity to Gentile, dismissed the due process false-evidence claim, and granted Monell summary judgment; McReynolds appealed.
The Eighth Circuit reversed qualified immunity for Schmidli on the excessive-force claim, affirmed qualified immunity for Gentile, affirmed dismissal of the false-evidence claim, and affirmed the Monell dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force / qualified immunity (Schmidli)	Schmidli used an objectively unreasonable violent takedown against a compliant, nonthreatening arrestee	Force was justified by McReynolds’ brief/nonimmediate compliance	Reversed: violation shown and right clearly established in June 2012; Schmidli not entitled to qualified immunity
Excessive force liability (Gentile)	Gentile participated in takedown and thus liable	Gentile only applied a wrist lock and did not contribute to the injurious force	Affirmed: Gentile entitled to qualified immunity; insufficient evidence he used or significantly contributed to excessive force
False reports / false evidence (substantive due process)	Officers deliberately fabricated reports and summons to frame McReynolds	Reports contained inaccuracies but no proof of deliberate fabrication to frame him	Affirmed: plaintiff failed to show deliberate manufacture of false evidence
Monell municipal liability	City maintained an unofficial custom of tolerating excessive force (pattern shown by McReynolds’ arrests)	Two incidents are insufficient to show a continuing, widespread, persistent pattern or failure to train	Affirmed: two incidents do not establish the necessary pattern or custom for Monell liability

Scott v. Harris, 550 U.S. 372 (U.S. 2007) (courts may refuse to credit a party’s version of events blatantly contradicted by record evidence)
Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (summary judgment standard requires no genuine issue of material fact)
Anderson v. Creighton, 483 U.S. 635 (U.S. 1987) (qualified immunity requires clearly established law)
Monell v. Dep’t of Social Servs., 436 U.S. 658 (U.S. 1978) (municipal liability requires a policy or custom causing constitutional violation)
Kelsay v. Ernst, 933 F.3d 975 (8th Cir. 2019) (use of force analysis where subject disregarded direct commands)
Neal v. Ficcadenti, 895 F.3d 576 (8th Cir. 2018) (force against a nonresisting, nonthreatening suspect violates clearly established law)
Montoya v. City of Flandreau, 669 F.3d 867 (8th Cir. 2012) (leg-sweep takedown of nonviolent misdemeanant unreasonable)
Karels v. Storz, 906 F.3d 740 (8th Cir. 2018) (takedown of nonthreatening suspect not objectively reasonable)
Shekleton v. Eichenberger, 677 F.3d 361 (8th Cir. 2012) (taser use against unarmed, nonresisting misdemeanant unreasonable)
Nance v. Sammis, 586 F.3d 604 (8th Cir. 2009) (summary judgment inappropriate when record does not conclusively establish lawfulness of force)