90 F.4th 541
6th Cir.2024Background
- Timmy Mosier was arrested for public intoxication and taken to the Crockett County Jail, where he resisted Deputy Joseph Evans while handcuffed.
- Evans pulled Mosier to the ground by his overall strap, causing Mosier to hit his head on the concrete and sustain serious injuries.
- Mosier filed suit alleging excessive force and inadequate medical care under 42 U.S.C. § 1983 against Evans and Crockett County, as well as related state-law negligence claims.
- The district court granted summary judgment to defendants on all federal claims based on qualified immunity and municipal liability standards, and largely dismissed the state-law claims under the Tennessee Governmental Tort Liability Act's (GTLA) civil-rights exception.
- On appeal, Mosier challenged the qualified immunity decision, the application of the GTLA civil-rights exception, and the dismissal of his negligence claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Qualified Immunity—Excessive Force (§1983 claim) | Evans used excessive force not justified by facts, violating clearly established law | Evans' force was reasonable and no clearly established law was violated | Affirmed; force not clearly established as unconstitutional under circuit precedent |
| Qualified Immunity—Inadequate Medical Care (§1983 claim) | Mosier did not brief this well but alleged inadequate care after injury | Care was prompt and met requirements; no clearly established violation | Affirmed; claim forfeited due to insufficient briefing |
| Municipal Liability (Monell claim) | County's policies or lack of adequate training caused violation of rights | No official policy, custom, or pattern linking county to the alleged violation | Affirmed; no evidence of municipal policy or deliberate indifference |
| Negligence Claims—GTLA Civil Rights Exception (against County and Evans official cap.) | Claims pled alternatively/concurrently as negligence, so GTLA exception not triggered | Claims arise from same facts as civil rights claims, so they're barred | Affirmed; negligence claims barred under GTLA's civil-rights exception |
| Negligence Claim—Personal Capacity (Evans) | GTLA does not shield employees personally for negligent acts | May be forfeited on appeal; should be dismissed as to Evans personally | Reversed; personal-capacity negligence claim may proceed |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard for constitutional torts)
- Graham v. Connor, 490 U.S. 386 (objective reasonableness standard governs claims of excessive force under the Fourth Amendment)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability under §1983 requires official policy or custom)
- Pearson v. Callahan, 555 U.S. 223 (steps for analyzing qualified immunity)
- City of Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train)
- Tennessee v. Garner, 471 U.S. 1 (limitation on deadly force by police under Fourth Amendment)
- Ashcroft v. al-Kidd, 563 U.S. 731 (specificity requirement for clearly established rights)
- Hope v. Pelzer, 536 U.S. 730 (fair warning standard for qualified immunity)
- Scott v. Harris, 550 U.S. 372 (use of video evidence in summary judgment on excessive force)
- Board of Cnty. Comm’rs of Bryan Cnty. v. Brown, 520 U.S. 397 (deliberate indifference in training standards for municipal liability)