William Cass v. City of Dayton, 770 F.3d 368

Detectives conducted a buy-bust at an Econo Lodge to arrest suspected dealer Robert Moore after a confidential informant signaled a deal.
A blue Ford Taurus with driver Charles Stargell stopped under the motel overhang; officers moved to arrest after the informant’s signal.
Detective House parked near the exit, approached the Taurus from the front with gun drawn and identified himself as police; the driver accelerated and struck House and another officer (St. Clair).
Moments after being struck and hearing a gunshot he believed to be fired in defense by St. Clair, House fired one shot at the driver; the bullet killed front-seat passenger Derrick Jordan (innocent bystander).
House and St. Clair were disciplined internally; Jordan’s estate sued under 42 U.S.C. § 1983 (excessive force) and Monell, and raised Ohio state-law claims. The district court granted summary judgment for defendants; estate appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether House used excessive force in violation of the Fourth Amendment	Estate: shooting was unreasonable because Jordan (victim) was not the intended target and officers were no longer in immediate path	House: shot was objectively reasonable given vehicle had struck officers and he reasonably believed others were in imminent danger	Court: No Fourth Amendment violation; use of deadly force was objectively reasonable under circumstances
Whether qualified immunity shields House	Estate: rights were clearly established and House’s conduct unreasonable	House: entitled to qualified immunity because conduct did not violate clearly established law	Court: Reached only whether a constitutional violation occurred and concluded none; therefore immunity analysis unnecessary beyond that finding
Municipal liability under Monell	Estate: City’s inadequate training/supervision and alleged failure to discipline created causal nexus	City: no underlying constitutional violation for Monell to attach	Court: Monell claim fails because no constitutional violation by House
State-law claims under Ohio Rev. Code § 2744.03	Estate: wrongful death/assault claims against House and City	Defendants: statutory immunity applies because conduct was within scope and not malicious, wanton, or reckless	Court: State-law claims fail because House did not act unreasonably; statutory immunity applies

Graham v. Connor, 490 U.S. 386 (objective reasonableness Fourth Amendment excessive-force framework)
Tennessee v. Garner, 471 U.S. 1 (deadly force against fleeing felony suspect limited to when suspect poses serious threat)
Monell v. Department of Social Services, 436 U.S. 658 (municipal liability requires underlying constitutional violation and policy/custom nexus)
Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard for government officials)
Malley v. Briggs, 475 U.S. 335 (scope of qualified immunity protection)
Saucier v. Katz, 553 U.S. 194 (two-step qualified immunity framework)
Plumhoff v. Rickard, 134 S. Ct. 2012 (reasonableness of deadly force in vehicular flight context)
Smith v. Cupp, 430 F.3d 766 (Sixth Circuit framework for deadly-force claims involving vehicles)