Rivas-Villegas v. Cortesluna, 595 U.S. 1

Officers responded to a 911 call from a 12‑year‑old saying she, her mother, and a sister had barricaded themselves because the mother’s boyfriend (Cortesluna) was trying to hurt them and there was sawing/noise consistent with a chainsaw.
Officers observed a man matching the description, confirmed the family could not exit, and announced police presence; Cortesluna initially dropped a metal tool when ordered to "drop it."
As Cortesluna walked toward officers, one officer observed a knife protruding from his left pocket; he lowered his hands contrary to commands and was shot twice with a beanbag round, after which he raised his hands and was ordered to get down.
Rivas‑Villegas then straddled Cortesluna, placed his left knee on the left side of Cortesluna’s back (near the pocket with the knife) for no more than eight seconds while assisting in removing the knife and securing his arms; another officer removed the knife and handcuffed Cortesluna.
Cortesluna sued under 42 U.S.C. § 1983 alleging excessive force; the district court granted summary judgment for Rivas‑Villegas, the Ninth Circuit reversed relying on LaLonde v. County of Riverside, and the Supreme Court granted certiorari.
The Supreme Court reversed the Ninth Circuit, holding LaLonde was materially distinguishable and that no clearly established law put Rivas‑Villegas on notice his brief knee placement violated the Fourth Amendment, so qualified immunity applies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rivas‑Villegas is entitled to qualified immunity for alleged excessive force	LaLonde and precedent put officers on notice that kneeling on a prone suspect's back during handcuffing is excessive force	The situation was materially different and more dangerous (reports of chainsaw, knife visible, suspect had just been shot with beanbags); knee was brief and near the knife while retrieving it	Court reversed Ninth Circuit: no clearly established law on these facts; qualified immunity granted
Whether circuit precedent (LaLonde) clearly established unlawfulness of this use of force	LaLonde is sufficiently similar to provide fair notice	LaLonde is materially distinguishable (noise complaint, unarmed, longer/different knee use) so it cannot clearly establish law here	Even assuming circuit precedent can clearly establish law, LaLonde did not; specificity required under Fourth Amendment jurisprudence

Cortesluna v. Leon, 979 F.3d 645 (9th Cir. 2020) (Ninth Circuit decision denying qualified immunity based on LaLonde)
LaLonde v. County of Riverside, 204 F.3d 947 (9th Cir. 2000) (Ninth Circuit case finding knee to back during handcuffing constituted excessive force)
White v. Pauly, 580 U.S. _ (2017) (qualified immunity requires that unlawfulness be clearly established in a particularized sense)
Mullenix v. Luna, 577 U.S. 7 (2015) (emphasizes context‑specific analysis and need for clear precedent)
Brosseau v. Haugen, 543 U.S. 194 (2004) (Fourth Amendment excessive‑force inquiry must account for the specific context)
Graham v. Connor, 490 U.S. 386 (1989) (governing reasonableness standard for excessive force claims)
Tennessee v. Garner, 471 U.S. 1 (1985) (deadly‑force principle: officers may use force to prevent escape if suspect poses serious threat)
Kisela v. Hughes, 584 U.S. _ (2018) (precedent with similar facts can be necessary to clearly establish constitutional violation)