William Thomas v. City of Columbus
854 F.3d 361
| 6th Cir. | 2017Background
- At ~8:45 a.m., two intruders forced their way into Destin Thomas’s apartment; Thomas called 911 and struggled with the burglars inside his bedroom.
- Columbus PD dispatched a “priority one” burglary-in-progress; Officer William Kaufman arrived first, alone, with his weapon unholstered.
- Two men exited the apartment toward Kaufman; the first held a gun. Kaufman stopped ~40 feet from the door, shouted, and fired two shots as the armed person closed to ~10 feet.
- The person shot was Destin Thomas, who had disarmed a burglar and was holding an unloaded gun; Thomas died. The fleeing burglar (witness) refused to testify.
- William Thomas sued under 42 U.S.C. § 1983 (excessive force and deliberate indifference to medical needs) and asserted Monell failure-to-train liability; defendants moved for summary judgment asserting qualified immunity.
- The district court granted summary judgment for defendants; the Sixth Circuit affirmed, holding Kaufman’s use of deadly force was objectively reasonable and there was no Fourteenth Amendment deliberate indifference or municipal liability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force (Fourth Amendment) — was deadly force reasonable? | Thomas argues Kaufman was not entitled to shoot because the decedent was the homeowner/victim and did not pose a threat; evidence does not establish Thomas pointed the gun. | Kaufman contends a reasonable officer could use deadly force when someone runs toward him holding a gun and closes rapidly from ~40 to ~10 feet. | Held: Use of deadly force was objectively reasonable under Graham/Tennessee v. Garner; qualified immunity applies even if jury disbelieves Kaufman. |
| Deliberate indifference to medical needs (Fourteenth Amendment) — did Kaufman unreasonably delay aid? | Thomas contends Kaufman failed to render or promptly secure medical aid, showing reckless disregard. | Kaufman argues he immediately called for medical assistance and remained cautious for safety at an active crime scene. | Held: No Fourteenth Amendment violation; summoning help and securing scene justified not rendering immediate aid. |
| Municipal liability / failure to train (Monell) | City and police chief failed to train Kaufman, causing constitutional violations. | Defendants argue no underlying constitutional violation occurred, so Monell claim fails. | Held: Dismissed — no § 1983 municipal liability without an underlying constitutional violation. |
| Reliance on hindsight and expert testimony | Thomas argues disputed facts and expert opinions create issues for trial; officer’s approach/procedures violations show negligence. | Defendants argue reasonableness is an objective legal question judged from the officer’s perspective at the moment; procedural violations are not dispositive of Fourth Amendment reasonableness. | Held: Court rejects hindsight and plaintiff expert’s legal conclusions; objective reasonableness resolved for defendant as a matter of law. |
Key Cases Cited
- Graham v. O'Connor, 490 U.S. 386 (1989) (objective-reasonableness standard for excessive-force claims)
- Tennessee v. Garner, 471 U.S. 1 (1985) (deadly force permissible when officer has probable cause to believe suspect poses significant threat of death or serious injury)
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability under § 1983 requires an underlying constitutional violation and policy/practice causation)
- Chappell v. City of Cleveland, 585 F.3d 901 (6th Cir. 2009) (courts assess officer reasonableness from officer's on-scene perspective; legal question for court)
- Livermore v. Lubelan, 476 F.3d 397 (6th Cir. 2007) (describes segmented analysis focusing on circumstances at the moment force used)