Nicholas Coffey v. Adam Carroll
933 F.3d 577
| 6th Cir. | 2019Background
- Coffey was tracked to his home after a reported attempted vehicle break-in; officers entered the house without a warrant and found Coffey asleep on a loveseat.
- Officers Carroll, Pranger, and Pilchak contend Coffey resisted arrest; Coffey and his father say Coffey was asleep, unresisting, and was roughly awakened, handcuffed, and dragged out causing facial injuries.
- Coffey was jailed, a felony warrant issued, then later tried on assault-on-officer charges and acquitted by a jury.
- Coffey sued the officers under 42 U.S.C. § 1983 for unlawful entry, excessive force, and malicious prosecution; the City was dismissed by stipulation.
- The district court denied summary judgment on unlawful entry, excessive force, and malicious-prosecution claims (except as to Pilchak on malicious prosecution). The officers appealed the denials invoking qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Unlawful entry (warrantless home entry) | Entry was without consent or exigency; Fourth Amendment violated | Entry was lawful because Coffey’s father consented, Coffey was in public view, or officers were in hot pursuit | Denied immunity: factual dispute on consent; not public view; no hot pursuit; right clearly established |
| Excessive force during arrest | Force used while Coffey was asleep/ not resisting; caused injuries | Force was reasonable because Coffey resisted (grabbed/twisted/kicked) | Denied immunity: admissible evidence; viewing facts for plaintiff, a jury could find force unreasonable; right clearly established |
| Malicious prosecution | Officers knowingly gave false testimony at preliminary hearing that led to prosecution | Officers merely performed investigative duties; did not cause prosecution | Denied immunity for Carroll and Pranger: their testimony at the preliminary hearing could have influenced prosecution and may have been false; factual issues for jury |
| Reviewability on interlocutory appeal | N/A | Some arguments are fact disputes not reviewable now | Court reviews legal questions de novo but defers disputed factual resolutions to district court/trial |
Key Cases Cited
- Mitchell v. Forsyth, 472 U.S. 511 (recognizing interlocutory appealability of qualified immunity)
- Payton v. New York, 445 U.S. 573 (warrantless home entry presumptively unreasonable)
- Santana, 427 U.S. 38 (public-view exception to home-protection rule)
- Matlock, 415 U.S. 164 (third-party consent to search)
- Welsh v. Wisconsin, 466 U.S. 740 (double-presumption against warrantless entry for misdemeanors)
- Warden v. Hayden, 387 U.S. 294 (hot-pursuit exigency exception)
- Graham v. Connor, 490 U.S. 386 (Fourth Amendment objective-reasonableness test for excessive force)
- Sykes v. Anderson, 625 F.3d 294 (officer testimony at preliminary hearing can show participation in prosecution decision)
- Fox v. DeSoto, 489 F.3d 227 (elements of malicious-prosecution claim under § 1983)
- Ashcroft v. al-Kidd, 563 U.S. 731 (doctrine on not defining rights at high level of generality for clearly established analysis)