Robert Shreve v. Franklin Cnty., Ohio, 743 F.3d 126

Putative class action against Franklin County, its sheriff and 14 deputies for excessive force and detainee privacy violations via strip searches; Michael Reed’s claims are before the court.
Reed alleges two incidents on January 29, 2009: a Cell Incident with Tasers during handcuffing, and a Hospital Incident where a deputy Tasers Reed at Mount Carmel West Hospital after Reed lunged.
Video of the Cell Incident is admitted; parties dispute whether force violated Reed’s rights under the Eighth or Fourteenth Amendments.
District court granted summary judgment on qualified immunity/constitutional grounds after finding no conscience-shocking malice or sadism.
The court applied Darrah v. City of Oak Park framework and concluded Reed failed to show deliberate indifference under the Fourteenth Amendment.
Monell claims against Franklin County were dismissed because no underlying constitutional violation was found.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Cell Incident tasings violated Reed’s due process rights	Reed claims deliberate indifference; video supports shock-the-conscience standard.	Deputies acted lawfully to subdue a noncompliant inmate and to ensure medical treatment.	NoFourteenth Amendment violation; actions not conscience-shocking.
Whether the Hospital Incident tasering violated Reed’s due process rights	Dishong tased Reed despite restraint, violating policy and rights.	Tasing occurred in a rapidly evolving, dangerous predicament with Reed lungeing toward staff.	No due process violation; actions not conscience-shocking.
Whether qualified immunity shields the individual deputies	Officers violated clearly established rights; video shows deliberate indifference.	No clearly established right violated; reasonable officers could have acted as they did.	Court did not reach clearly established analysis on this record; no constitutional violation found thus immunity not reached.
Whether Monell claims against Franklin County survive	County policy or custom caused constitutional rights violations.	No underlying constitutional violation, so Monell claim fails.	Monell claims dismissed; no liability without a constitutional violation.

Darrah v. City of Oak Park, 255 F.3d 301 (6th Cir.2001) (establishes deliberate indifference standard under Fourteenth Amendment in rapid-pursuit contexts)
Lanman v. Hinson, 529 F.3d 673 (6th Cir.2008) (distinguishes Fourth vs. Fourteenth Amendment standards based on pretrial status)
Graham v. Connor, 490 U.S. 386 (1989) (objective reasonableness standard for excessive force in Fourth Amendment contexts)
Scott v. Harris, 550 U.S. 372 (2007) (video cannot be ignored when it blatantly contradicts opposing testimony at summary judgment)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (summary judgment standard; need for evidence showing genuine dispute)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (threshold for denying summary judgment; evidence must show genuine dispute)