Roger Poole v. City of Shreveport, 2012 U.S. App. LEXIS 17243

Poole was arrested after a traffic stop in Shreveport, Louisiana, with a videotape capturing most events.
Creighton, off-duty and in plain clothes, tailgated Poole and prompted a marked-unit response; Stalnaker arrived and pursued Poole.
Poole was detained for insurance issues, admitted alcohol consumption, and failed to surrender when instructed; a struggle followed.
Creighton twisted Poole’s left arm; Stalnaker used a Taser; Poole ended on the ground with a dislocated elbow and broken arm.
Medical treatment followed; Poole alleged excessive force under 42 U.S.C. § 1983; district court granted summary judgment for defendants.
The Fifth Circuit affirmed summary judgment for Creighton, Stalnaker, City, and VanSant; discussed qualified immunity and policy claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Creighton and Stalnaker are entitled to qualified immunity	Poole asserts officers used clearly excessive force.	Officers' actions were objectively reasonable given resistance and threat.	Affirmed qualified immunity for Creighton and Stalnaker.
Whether City and VanSant failed to train or implement policies causing violation	Deliberate indifference evidenced by training/policy gaps.	No pattern or policy gap shown; training and policies are adequate.	Dismissing policy-based § 1983 claim; no deliberate indifference shown.

Graham v. Connor, 490 U.S. 386 (U.S. 1989) (objective reasonableness standard for excessive force)
Deville v. Marcantel, 567 F.3d 156 (5th Cir. 2009) (Graham factors; reasonableness of force in traffic-stop context)
Ontiveros v. City of Rosenberg, 564 F.3d 379 (5th Cir. 2009) (three-part test for qualified immunity in excessive force)
Goodson v. City of Corpus Christi, 202 F.3d 730 (5th Cir. 2000) (fact issues preclude summary judgment on objective reasonableness)
Randell v. Davis, 986 F.2d 1419 (5th Cir. 1993) (clearly established right violated in excessive force context)