Shira Jean Stafford v. Jackson County, Tennessee
M2016-01833-COA-R3-CV
| Tenn. Ct. App. | Aug 4, 2017Background
- On Nov. 16, 2010, Deputy Chris Carter stopped Donnie Stafford for speeding; Donnie’s wife Shira (Mrs. Stafford) arrived, approached the deputy, refused to follow his instructions, and was arrested for obstructing an officer.
- Mrs. Stafford was handcuffed at the scene; she alleges Carter pulled up on the middle of the handcuff chain after cuffing her, causing pain in her wrists and right shoulder.
- Mrs. Stafford was convicted in criminal court of obstructing an officer; the civil suit was stayed during appeals and later resumed. Plaintiffs sued Deputy Carter, Sheriff Brad Stafford, and Jackson County on multiple theories; many claims were later conceded by plaintiffs.
- Defendants moved for summary judgment relying on depositions and excerpts of the criminal trial transcript; the trial court granted summary judgment dismissing all claims, finding (1) a factual question existed on excessive force but (2) plaintiffs produced insufficient evidence of damages for assault and battery and (3) no actionable intentional infliction of emotional distress (IIED).
- On appeal, the Court of Appeals affirmed summary judgment on IIED but reversed as to assault and battery, holding there are genuine issues of material fact as to excessive force and damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether deputy’s conduct after handcuffing constituted excessive force/battery | Carter pulled up on the handcuff chain after cuffing Shira, causing pain; such post‑cuff pulling can be excessive force | Handcuffing was routine and not excessive; post‑cuff conduct does not amount to excessive force as alleged | Question of fact exists; summary judgment on excessive force improper |
| Whether plaintiff established compensable injury/damages for battery | Mrs. Stafford cried out in pain, reported pain to jail staff, sought ER care same evening; pain and limited functional loss are enough | Evidence of only minor, transient pain is insufficient to prove damages | Court held pain and medical treatment created a genuine factual dispute as to damages; summary judgment improper |
| Whether conduct was extreme/outrageous for IIED | Pulling up on handcuffs causing a torn rotator cuff and ongoing distress supports IIED | Conduct not so extreme; no evidence of serious mental injury | Affirmed for defendants: plaintiffs failed to show extreme conduct and serious mental injury for IIED |
| Whether additional claims survived after findings | Plaintiffs had conceded several claims; remaining claims depend on excessive force and damages | Defendants sought dismissal of all claims | Court affirmed dismissal of IIED and reversed dismissal of assault/battery; remanded for further proceedings |
Key Cases Cited
- City of Mason v. Banks, 581 S.W.2d 621 (Tenn. 1979) (police privileged to use only force necessary to effect arrest; excessive force exposes officer to battery liability)
- Bain v. Wells, 936 S.W.2d 618 (Tenn. 1997) (adopting high threshold for IIED; liability only where conduct is outrageous beyond all bounds of decency)
- Vance v. Wade, 546 F.3d 774 (6th Cir. 2008) (excessive‑force claim based on handcuffing requires tightness plus ignored complaints; pulling up on handcuffs may support excessive force claim)
- Morrison v. Board of Trustees of Green Township, 583 F.3d 394 (6th Cir. 2009) (gratuitous force against handcuffed detainee may be unreasonable even where physical injury is minimal)
- Martin v. Heideman, 106 F.3d 1308 (6th Cir. 1997) (pain and numbness from handcuffs can create genuine issue on excessive force despite lack of lasting injury)