Richard Rockwell v. City of Garland, Texas
2011 U.S. App. LEXIS 24980
| 5th Cir. | 2011Background
- Garland, Texas police breached Scott Rockwell’s locked bedroom door to arrest him for threatening his mother on Feb. 14, 2006.
- Scott Rockwell attacked officers with two knives after the breach; four officers fired, killing him.
- Rockwells sued for excessive force, assault and battery, and unlawful entry; district court granted summary judgment based on qualified immunity and official immunity.
- Scott suffered bipolar disorder, schizophrenia, and suicidal tendencies, with recent noncompliance with medications and deteriorating stability.
- Officers believed Scott posed threat; breach occurred after failed attempts to detain him; shots followed the confrontation in a narrow hallway.
- Court affirms summary judgment on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the officers violated the Fourth Amendment by using deadly force. | Rockwells contend excessive force; need clearly established rights. | Officers acted to protect themselves; Scott posed imminent threat. | Yes, Officers’ use of deadly force was objectively reasonable. |
| Whether the assault-and-battery claims survive official-immunity analysis. | Rockwells argue lack of good faith/official immunity. | Officers acted in good faith under totality of circumstances. | Official immunity affirmed; deadly force deemed reasonable. |
| Whether the warrantless entry into Scott’s room was unconstitutional. | Breaching the door violated Fourth Amendment without clear exigent grounds. | Exigent circumstances justified entry; consent disputed. | Qualified immunity; entry not clearly unlawful under the circumstances. |
| Whether the warrantless arrest for misdemeanor was constitutional. | No probable cause without witnessing the misdemeanor. | Law unsettled on warrantless misdemeanor arrests; qualified immunity applies. | Qualified immunity; no clearly established illegality at the time. |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (1989) (objective reasonableness in force decisions; split-second judgments)
- Tennessee v. Garner, 471 U.S. 1 (1985) (deadly force only for imminent threat; flight not enough)
- Bazán v. Hidalgo Cnty., 246 F.3d 481 (5th Cir.2001) (excessive-force inquiry focuses on danger at moment of threat)
- Gates v. Texas Dep’t of Protective & Regulatory Servs., 537 F.3d 404 (5th Cir.2008) (reasonableness framework for Fourth Amendment claims in probation/inspection contexts)
- Brigham City v. Stuart, 547 U.S. 398 (2006) (exigent-circumstances doctrine; entry to assist imminent danger)
- Pierce v. Smith, 117 F.3d 866 (5th Cir.1997) (qualified immunity/entry analysis in warrantless-search contexts)
- Russo v. City of Cincinnati, 953 F.2d 1036 (6th Cir.1992) (exigency and suicidal-threat scenarios; qualified immunity)