Starrett v. City of Lander, 699 F. App'x 805

Officers Ramsey and Romero responded to a verbal domestic disturbance at the Starretts’ trailer; Mr. Starrett agreed to leave and went into the trailer to get shoes while Romero followed.
Joanna Starrett stepped into the doorway and closed the front door, telling Romero he could not enter without a warrant; Officer Ramsey then took her to the ground, and she alleges a broken arm.
Both officers arrested Joanna under a municipal interference/obstruction charge; she sued under 42 U.S.C. § 1983 for unlawful arrest and excessive force, plus state-law claims.
The district court granted summary judgment to the officers based on qualified immunity and declined supplemental jurisdiction over state claims; Starrett appealed only the qualified-immunity rulings.
On appeal the Tenth Circuit reviewed de novo, viewed disputed facts in Starrett’s favor where appropriate, but affirmed qualified immunity for (1) arguable probable cause to arrest for interference and (2) no clearly established Fourth Amendment violation for the takedown.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unlawful arrest — was there probable cause to arrest Starrett for interfering with an officer?	Starrett: she had a Fourth Amendment right to revoke any consent and to refuse entry; shutting the door was passive refusal, so no probable cause.	Officers: Starrett blocked Romero’s path and line of sight, posed an active interference with a lawful performance of duties, so there was arguable probable cause under Wyoming law.	Held: Officers had arguable probable cause; qualified immunity for unlawful-arrest claim affirmed.
Excessive force — was Ramsey’s takedown objectively unreasonable?	Starrett: Ramsey intentionally and without warning threw her to the ground immediately after she shut the door, amounting to excessive force.	Officers: Given the tense domestic call, possible intoxication, and history suggesting a firearm, Ramsey reasonably perceived an immediate safety risk; split-second judgment justified force.	Held: No clearly established Fourth Amendment violation under controlling precedent; qualified immunity for excessive-force claim affirmed.

Harlow v. Fitzgerald, 457 U.S. 800 (Sup. Ct. 1982) (qualified immunity framework)
White v. Pauly, 137 S. Ct. 548 (Sup. Ct. 2017) (clearly established law must be particularized)
Mullenix v. Luna, 136 S. Ct. 305 (Sup. Ct. 2015) (existing precedent must place question beyond debate)
Graham v. Connor, 490 U.S. 386 (Sup. Ct. 1989) (objective-reasonableness standard for excessive force)
Georgia v. Randolph, 547 U.S. 103 (Sup. Ct. 2006) (third-party consent and right to refuse entry)
Morris v. Noe, 672 F.3d 1185 (10th Cir. 2012) (analyzing takedown force where underlying offense was misdemeanor)
Dolson v. United States, 948 A.2d 1193 (D.C. 2008) (closing or reinforcing barriers can constitute interference; discussion of right to resist unlawful searches)