Susan Davenport v. City of Little Rock
142 F.4th 1036
8th Cir.2025Background
- Law enforcement conducted simultaneous no-knock narcotics raids on a home and shop in Pulaski County, Arkansas following suspicions of drug activity.
- The searches resulted in the recovery of contraband from both locations, and during the raid of the shop, Officer Thomas shot and injured Lloyd St. Clair, who was holding a shotgun.
- Lloyd, Floyd, Chris, and Susan (residents and present parties) were charged with drug and related offenses; Lloyd and Floyd pleaded guilty.
- Plaintiffs brought a 42 U.S.C. § 1983 action, alleging Fourth Amendment violations: unlawful search, unlawful entry, excessive force, and municipal liability under Monell.
- The district court granted summary judgment for the defendants (officers, city, and police chief), and plaintiffs appealed.
- The appellate court reviewed the record de novo, affirming summary judgment on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence of Home Search Warrant | Warrant for the home was fabricated after the fact | Both warrants existed and were valid, corroborated by court records and officer statements | No genuine dispute: both warrants existed; summary judgment affirmed |
| Justification for No-Knock Entry | Officers lacked reasonable suspicion for no-knock entry; relied on ambiguous evidence | Reasonable suspicion based on videos of firearm use at the property; SWAT informed pre-raid | No material dispute; testimony supported reasonable suspicion; summary judgment affirmed |
| Excessive Force Against Lloyd St. Clair | Thomas unreasonably shot Lloyd, excessive under Fourth Amendment | Lloyd pointed shotgun at Thomas; force was objectively reasonable under circumstances | Deadly force justified; Lloyd admitted pointing gun; summary judgment affirmed |
| Municipal Liability (Monell) | City liable for constitutional violations by officers | No underlying constitutional violation; no Monell liability | Absent violation by city employee, no city liability; summary judgment affirmed |
Key Cases Cited
- Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (summary judgment standard for genuine dispute of material fact)
- Richards v. Wisconsin, 520 U.S. 385 (1997) (standard for no-knock warrants, requiring reasonable suspicion of exigent circumstances)
- Wallace v. City of Alexander, 843 F.3d 763 (8th Cir. 2016) (factors for analyzing use of deadly force under Fourth Amendment)
- Partlow v. Stadler, 774 F.3d 497 (8th Cir. 2014) (deadly force reasonable if officer believes suspect is pointing a gun)
- Whitney v. City of St. Louis, 887 F.3d 857 (8th Cir. 2018) (no Monell liability without underlying constitutional violation)