Scott Peatross v. City of Memphis
818 F.3d 233
| 6th Cir. | 2016Background
- On April 23, 2013, MPD Officers Dunaway and McMillen fired seven shots into the vehicle driven by Anjustine Vanterpool, killing him; estate sued under 42 U.S.C. § 1983.
- The Estate alleged excessive-force Fourth Amendment claims against the shooters and supervisory-liability claims against MPD Director Toney Armstrong in his individual capacity.
- Complaint alleges a pattern of MPD shootings (54 from 2009–2013; 18 in one year), public admonishment of Armstrong, failure to reform discipline/training, and a practice of “rubber-stamping” officer misconduct.
- Armstrong moved to dismiss asserting qualified immunity; the district court denied the motion, finding the complaint plausibly alleged Armstrong implicitly authorized or knowingly acquiesced in unconstitutional conduct and that the right was clearly established.
- Armstrong conceded the Complaint’s factual allegations for the appeal; the Sixth Circuit reviewed de novo whether the alleged facts state a violation of clearly established law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Armstrong is entitled to qualified immunity for supervisory liability | Armstrong knowingly acquiesced in and ratified unconstitutional conduct; failure to train/supervise and exonerations link him to the violation | Qualified immunity shields Armstrong; supervisory liability requires more than alleged failures and cannot rest on respondeat superior | Denied: complaint plausibly alleges Armstrong knowingly acquiesced and is not entitled to immunity at pleading stage |
| Whether the complaint pleads an actionable theory of supervisory liability | Estate: allegations of pattern, inaction after public admonishment, and ‘‘rubber-stamping’’ constitute active conduct/ratification | Armstrong: supervisory liability requires specific acts beyond general failure to supervise or provide training | Held: allegations meet minimal supervisory-liability pleading standard (implicit authorization/approval/knowing acquiescence) |
| Whether there is a causal connection between Armstrong’s conduct and Vanterpool’s death | Estate: Armstrong’s policies/inaction could reasonably be expected to produce officer shootings like Vanterpool’s | Armstrong: too attenuated; supervisors not liable for every subordinate violation | Held: complaint plausibly alleges causation (acts/omissions proximately linked to injury) |
| Whether the violated right was "clearly established" | Estate: Fourth Amendment prohibition on unreasonable seizures and excessive force was clearly established | Armstrong: claims rest on supervisory liability and alleged right to training, which is not a freestanding clearly established right | Held: Right violated by officers was clearly established; plaintiff need not show a freestanding right to training |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (limits on supervisory liability in § 1983 suits)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity; early-stage resolution)
- Graham v. Connor, 490 U.S. 386 (objective-reasonableness standard for force claims)
- Coley v. Lucas Cty., 799 F.3d 530 (6th Cir. 2015) (supervisory acquiescence and pleading sufficiency)
- Campbell v. City of Springboro, 700 F.3d 779 (6th Cir. 2012) (causal link between supervisory omission and constitutional injury)
- Leach v. Shelby Cty. Sheriff, 891 F.2d 1241 (6th Cir. 1989) (personal liability for supervisory conduct)