Morris v. Town of Lexington Alabama
748 F.3d 1316
11th Cir.2014Background
- Morris's home was entered by Lexington and Anderson officers without a warrant in the early morning after a 911 call about a potentially endangered woman.
- The officers encountered Morris as he awoke; Bradford blocked the doorway and refused to leave; Morris told them to leave and that a warrant was needed for entry.
- Bradford, Wigginton, and Bowers entered Morris's residence; Morris tried to close the door and was shoved; Bradford detained Morris in the doorway.
- Morris punched Bradford in response to the detention; officers then entered the home, subdued Morris with a taser, and searched the residence.
- Morris was charged with assault and resisting arrest in Lauderdale County; the charges were later dismissed/returned after grand jury actions; Morris filed a §1983 suit in the Northern District of Alabama.
- The District Court denied qualified-immunity defenses as to Counts I (warrantless entry) and II (unlawful arrest); the appeal concerns whether those denials were proper.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether warrantless entry violated the Fourth Amendment. | Morris; entry was without warrant or probable cause | Bradford/Bowers; possible exception to warrant requirement via suspicion | Count I reversible/affirmed denial of immunity; entry unlawful |
| Whether Morris's arrest was supported by probable or arguable probable cause. | Morris; arrest lacked probable cause | Bradford/Bowers; arrest supported by probable/arguable probable cause | Count II upheld as non-violation; district court erred in denying dismissal |
Key Cases Cited
- Payton v. New York, 445 U.S. 573 (U.S. 1980) (home entry presumptively unreasonable without a warrant)
- Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (home entry without warrant presumptively unreasonable)
- Florida v. Jardines, 133 S. Ct. 1409 (S. Ct. 2013) (home is first among equals for Fourth Amendment concerns)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (two-step qualified immunity framework; right must be clearly established)
- Anderson v. Creighton, 483 U.S. 635 (U.S. 1987) (analysis of clearly established rights in qualified immunity)
- Ashcroft v. al-Kidd, 131 S. Ct. 2074 (S. Ct. 2011) (clearly established standard; not necessary to have case on point)