Sanchez v. Guzman, 105 F.4th 1285

Plaintiffs (Marta Sanchez, Estate of Stephanie Lopez, and Dominic Martinez) brought a § 1983 action alleging excessive force by Littleton and Englewood, Colorado Police after officers fired 66 bullets into their vehicle, killing Lopez, paralyzing Sanchez, and injuring Martinez.
The incident followed a police pursuit after a reported armed carjacking, involving high-speed chases and attempted police stops across multiple jurisdictions.
Plaintiffs claimed they were trying to surrender and posed no threat when officers used lethal force; defendants argued plaintiffs used the car as a weapon and endangered public safety.
The district court granted summary judgment for defendants on qualified immunity, finding plaintiffs failed to demonstrate a violation of clearly established law.
Plaintiffs appealed, arguing the district court misapplied the burden and ignored evidence favorable to them.
On appeal, the Tenth Circuit affirmed, holding plaintiffs failed to provide a record-supported factual narrative necessary to overcome qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Burden of proof on qualified immunity	Plaintiffs argued the district court wrongly placed the burden on them to disprove qualified immunity.	Defendants relied on circuit law holding the plaintiff bears the burden after immunity is asserted.	Court ruled that plaintiffs bear the burden.
Definition of operative facts	Plaintiffs claimed the court ignored or marginalized their version of events and improperly weighed the evidence.	Defendants argued the record supports their version, including video evidence.	Court found plaintiffs failed to provide a record-supported factual narrative; review waived.
Clearly established law prong	Plaintiffs contended they were not required to produce case law with identical facts and had met their burden.	Defendants asserted no case law precluded the officers' conduct under materially similar circumstances.	Court held plaintiffs didn't ground their version in the record; court couldn't assess the law.
Court's treatment of factual disputes	Plaintiffs claimed the court should have credited their evidence and resolved factual disputes in their favor.	Defendants contended the court properly relied on undisputed and video evidence.	Court noted its skepticism but still required plaintiffs to create a record-based factual universe; affirmed judgment.

Mullenix v. Luna, 577 U.S. 7 (qualified immunity shields officials unless law is clearly established).
Graham v. Connor, 490 U.S. 386 (seminal standard for excessive force claims under the Fourth Amendment).
Tennessee v. Garner, 471 U.S. 1 (use of deadly force under the Fourth Amendment must be reasonable).
Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established law must be particularized to the facts of each case).
Pearson v. Callahan, 555 U.S. 223 (established two-prong qualified immunity framework).
Scott v. Harris, 550 U.S. 372 (where video evidence clearly contradicts parties' narrative, courts should view the facts in the light depicted by the video).