Nathan Rice v. Reliastar Life Insurance Co.
770 F.3d 1122
| 5th Cir. | 2014Background
- Deputies Arnold and Johnson responded to a 911 call reporting Gerald Rice sitting in his truck in his garage with a loaded gun and threatening suicide; family reported Rice had been drinking and taken medication.
- Deputies entered the home without a warrant, exchanged commands with Rice, heard a single gunshot (into the garage wall), and retreated; Rice exited his truck and, while walking toward the house, stated “I want to commit suicide.” Arnold fired four shots, hitting Rice three times; Rice died.
- Rice’s beneficiaries (the Rice Plaintiffs) sued Arnold and Sheriff Graves (respondeat superior) for federal constitutional and Louisiana state tort claims; defendants moved for summary judgment asserting qualified immunity and other defenses; district court granted summary judgment for Arnold and Graves.
- Separately, the Rice Plaintiffs sued ReliaStar for $179,000 accidental death benefits under an ERISA-covered group life policy; ReliaStar denied the claim after appeals and the district court granted summary judgment for ReliaStar (abuse-of-discretion review).
- On appeal the Fifth Circuit addressed: (1) whether an officer may enter a home without a warrant to prevent self-directed harm (exigent circumstances); (2) whether Arnold’s use of deadly force was excessive; (3) related Louisiana tort claims; and (4) whether ReliaStar abused its discretion in denying accidental death benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Warrantless entry (Fourth Amendment/exigent circumstances) | Entry was unlawful because there was no shooting at the time of entry and officers should have waited for a special response team | Exigent circumstances justified entry: reliable report Rice was suicidal, armed, intoxicated and posed imminent risk to himself | Entry justified; officer entitled to qualified immunity — an individual’s threat to self can create exigency permitting warrantless entry |
| Excessive force (use of deadly force) | Genuine disputes (gun hand, location) and officer’s temperament preclude summary judgment | Audio record and facts show Rice was armed, refused commands, advanced toward officers; use of deadly force was objectively reasonable | No constitutional violation; Arnold entitled to qualified immunity because deadly force was reasonable given threat of serious harm |
| State torts (assault/battery, false imprisonment, IIED) | State claims survive because force was excessive and detention unlawful; IIED supported by alleged MySpace evidence | Actions were reasonable under circumstances; Rice not totally restrained; MySpace printout not linked to Arnold | Summary judgment for defendants affirmed on all state-law claims: force reasonable, no false imprisonment, IIED not established |
| ERISA accidental death benefit denial | ReliaStar’s denial was arbitrary; conflict of interest and presumption favoring accidental death should have weighed against insurer | ReliaStar’s decision was supported by substantial evidence (suicidal indicia, intoxication, pills, statement, conduct); conflict is merely a factor in abuse-of-discretion review | ReliaStar did not abuse its discretion; denial affirmed — death could be found non-accidental under the plan’s test |
Key Cases Cited
- Brigham City v. Stuart, 547 U.S. 398 (2006) (exigent-circumstances rule allowing warrantless entry to render emergency aid)
- Graham v. Connor, 490 U.S. 386 (1989) (objective-reasonableness standard for excessive-force claims)
- Tennessee v. Garner, 471 U.S. 1 (1985) (deadly force reasonable when officer has probable cause to believe suspect poses serious threat)
- Rockwell v. Brown, 664 F.3d 985 (5th Cir. 2011) (officers entitled to qualified immunity when responding to suicidal individual who posed threat)
- Fitzgerald v. Santoro, 707 F.3d 725 (7th Cir. 2013) (warrantless entry constitutional where officers reasonably believed entry necessary to prevent self-harm)
- Metropolitan Life Ins. Co. v. Glenn, 544 U.S. 105 (2005) (insurer-evaluator conflict of interest is a factor under abuse-of-discretion review)
- Todd v. AIF Life Ins., 47 F.3d 1448 (5th Cir. 1995) (accidental-death inquiry has subjective and objective components)