Scott Lee Rudlaff v. Brandon Gillispie
791 F.3d 638
| 6th Cir. | 2015Background
- Deputies Gillispie and Bielski stopped Lawrence Carpenter for driving with a suspended license; dash-cam videos capture the encounter.
- Carpenter exited his truck but refused commands to place his hands on the truck and twice pulled/jerked his arms away while an officer attempted to handcuff him.
- Gillispie delivered a knee strike to compel compliance; Bielski warned Carpenter and then discharged a taser once, after which Carpenter fell and was handcuffed.
- Carpenter sued for excessive force under the Fourth Amendment; the district court denied summary judgment for the officers citing disputed facts.
- The officers appealed on qualified-immunity grounds; the Sixth Circuit treated the dash-cam videos as depicting the controlling facts.
- The Sixth Circuit majority held the force was reasonable because Carpenter actively resisted; a concurrence would find the force excessive but agrees qualified immunity applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether knee strike and single taser shot constituted excessive force | Carpenter: force was excessive; he was complying or not resisting sufficiently | Officers: Carpenter actively resisted, justifying force to subdue him | Majority: Not excessive — Carpenter actively resisted; force permissible |
| Whether facts must be viewed in plaintiff's favor given dash-cam evidence | Carpenter: video does not conclusively refute his version; draw inferences for plaintiff | Officers: video depicts events; court may view facts as shown on video | Court: where video captures genuinely disputed facts, view facts as video depicts (Scott v. Harris controlling) |
| Whether a de minimis-resistance rule limits use of force | Carpenter: even minor resistance here did not justify taser; de minimis rule should apply | Officers: no de minimis exception; resisting (arm swings, locking up) permits force | Court: rejects de minimis exception; active resistance permits taser/knee strike |
| Whether officers are entitled to qualified immunity if constitutional violation is debatable | Carpenter: conduct violated Fourth Amendment; denial of summary judgment was error | Officers: even if violation, law was not clearly established beyond debate | Court: even assuming violation, qualified immunity applies because law not clearly established |
Key Cases Cited
- Scott v. Harris, 550 U.S. 372 (video evidence can control facts on summary judgment)
- Graham v. Connor, 490 U.S. 386 (reasonableness standard for use of force under the Fourth Amendment)
- Pearson v. Callahan, 555 U.S. 223 (qualified-immunity framework)
- Hagans v. Franklin Cnty. Sheriff’s Office, 695 F.3d 505 (6th Cir. 2012) (taser permissible where suspect actively resists)
- Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established law must be beyond debate for qualified immunity)
- Saucier v. Katz, 533 U.S. 194 (qualified immunity and hazy border between lawful and unlawful conduct)
- Brosseau v. Haugen, 543 U.S. 194 (qualified immunity in excessive-force cases)