Steven Taylor v. Robert Caples, 2 F.4th 1124

Taylor, an adjunct professor and union representative, attended an October 19, 2017 St. Louis Community College Board meeting where a new no-clapping rule had been adopted.
After Taylor and others clapped, Board Vice Chair Rodney Gee warned the audience; Taylor stood and walked partway down the aisle toward the Board objecting to unequal enforcement.
Gee ordered Taylor to leave; he did not; Gee instructed officers (including Caples) to remove him. Video of the interaction is inconclusive about what happened next.
Taylor says Caples approached from behind, bumped him, yanked his jacket, performed a leg sweep, drove him face-first to the floor, kneeled and began to handcuff him; Caples says Taylor charged the table and he acted to restrain him.
Taylor was arrested (resisting dismissed; disturbance charge later resulted in acquittal), sued in state court, defendants removed to federal court, and only Taylor’s excessive-force claim against Caples survived dismissal; the district court denied Caples qualified immunity, finding material factual disputes.
The panel dismissed Caples’s interlocutory appeal for lack of jurisdiction because resolving the qualified-immunity issue would require resolving those disputed facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether this court has jurisdiction to review denial of qualified immunity	Taylor: district court correctly found genuine factual disputes precluding immunity	Caples: entitlement to immunity as a matter of law because his use of force was objectively reasonable	Dismissed appeal for lack of jurisdiction because core disputes are factual and cannot be resolved on interlocutory review
Whether Caples’s use of force violated clearly established law	Taylor: force was excessive under the facts as construed in his favor	Caples: Taylor charged the table, so force was reasonable and lawful	Court did not reach the merits; factual disputes prevented legal determination on appeal

Thompson v. Murray, 800 F.3d 979 (8th Cir. 2015) (jurisdictional principles for interlocutory review of qualified immunity)
Walton v. Dawson, 752 F.3d 1109 (8th Cir. 2014) (qualified immunity interlocutory-review standards)
Thurmond v. Andrews, 972 F.3d 1007 (8th Cir. 2020) (scope of appellate review limited to purely legal questions)
White v. McKinley, 519 F.3d 806 (8th Cir. 2008) (lack of jurisdiction where dispute at heart is factual)
Johnson v. Jones, 515 U.S. 304 (U.S. 1995) (appellate courts cannot resolve genuine factual disputes on interlocutory appeal)
Berry v. Doss, 900 F.3d 1017 (8th Cir. 2018) (officials cannot recast factual disputes as legal questions to create jurisdiction)
Riggs v. Gibbs, 923 F.3d 518 (8th Cir. 2019) (dismissing qualified-immunity appeal where material factual disputes were central)
Graham v. St. Louis Metro. Police Dep’t, 933 F.3d 1007 (8th Cir. 2019) (same: dismissal where appeal rests on disputed factual findings)