William Meyers, Sr. v. Baltimore County, Maryland
2013 U.S. App. LEXIS 2282
| 4th Cir. | 2013Background
- Officers entered Ryan Meyers’ residence to arrest him after a domestic-violence report, during which Officer Mee tasered Ryan ten times, culminating in Ryan’s death.
- District court granted summary judgment for three officers on qualified immunity grounds; plaintiff appeal argues excessive force and related state-law claims.
- Ryan, diagnosed with bipolar disorder, had a history of police detentions; prior calls to police over years noted concerns about his mental illness and volatility.
- The court weighs a two-step qualified-immunity framework (Saucier/Pearson) and accepts plaintiff-favorable facts for purposes of summary judgment.
- The court views the record in the plaintiff’s favor and notes credibility determinations are for a jury, not the court at the summary-judgment stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether entry and initial seizure were supported by probable cause | Meyers argued entry lacked probable cause | Officers had probable cause to arrest for domestic assault | Probable cause supported entry; Romeo and Gaedke entitled to immunity |
| Whether Mee’s first three taser uses were reasonable | First three taser shocks were excessive | Shocks were reasonable given Ryan’s threat while armed | First three uses were objectively reasonable; no immunity issue for Mee on these |
| Whether the seven additional taser shocks after Ryan fell were excessive | Continued shocks after restraint violated rights | Officer acted to subdue a resisting suspect | Seven additional shocks were excessive; Mee not entitled to qualified immunity on these |
| Whether the clearly established-rights prong defeats immunity for Mee | Rights violation was clearly established | No clearly established precedent on continued tasings in these facts | No qualified immunity for Mee; district court erred in granting immunity |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (U.S. 1989) (standard of objective reasonableness for excessive force)
- Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (two-step qualified-immunity framework (often adjusted))
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (modifies Saucier sequencing; courts may choose order of prongs)
- Park v. Shiflett, 250 F.3d 843 (4th Cir. 2001) (probable cause to arrest for domestic assault allows warrantless arrest)
- Bailey v. Kennedy, 349 F.3d 731 (4th Cir. 2003) (unnecessary, gratuitous, disproportionate force precludes immunity)