Young v. County of Los Angeles
2011 U.S. App. LEXIS 17829
9th Cir.2011Background
- Young was stopped for a seatbelt violation; Wells observed additional issues including missing side-mirror and rear license plate.
- Young exited his truck, provided registration, and sat on the curb eating vegetables while Wells completed the citation.
- Wells ordered Young to sit in the truck; Young refused and remained on the curb, continuing to discuss the situation.
- Wells pepper sprayed Young from behind as Young rose to leave, and Wells then struck him with a baton while Young protested.
- Second deputy Berk arrived, handcuffed Young, and kept his knee on Young's back while Young complained of pain.
- Young sued for excessive force, false imprisonment, and negligence; the district court granted summary judgment on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force under Fourth Amendment | Young argues pepper spray and baton blows were excessive. | Wells argues force was reasonable given safety concerns and resistance. | Excessive force; not reasonable under Graham framework. |
| False imprisonment | Young asserts unlawful confinement without privilege. | Wells had lawful authority to arrest for disobedience of a lawful order. | Lawful privilege to arrest; false imprisonment not established. |
| Qualified immunity | Rights were clearly established; officers could not use such force. | If not clearly established, qualified immunity protects officers. | Not entitled to qualified immunity; clearly established law supported excessive force finding. |
Key Cases Cited
- Graham v. Connor, 490 F.2d 386 (U.S. 1989) (reasonableness balancing framework for police use of force)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (how to analyze qualified immunity when law is clearly established)
- Blankenhorn v. City of Orange, 485 F.3d 463 (9th Cir. 2007) (notice of unreasonableness of force; lack of warning; no act of resistance required)
- Headwaters Forest Defense v. County of Humboldt, 276 F.3d 1125 (9th Cir. 2002) (pepper spray excessive when used on non-violent protesters with no threat)
- Deorle v. Rutherford, 272 F.3d 1272 (9th Cir. 2001) (objective factors needed to justify officer safety concerns; warnings considered)
- Miller v. City of Clark County, 340 F.3d 959 (9th Cir. 2003) (three-factor assessment of government's interest; gravity of intrusion)
- United States v. Neill, 166 F.3d 943 (9th Cir. 1999) (pepper spray described as a dangerous weapon in certain contexts)
- Headwaters Forest Defense v. County of Humboldt, 276 F.3d 1125 (9th Cir. 2002) (pepper spray excessive against non-threatening non-violent conduct)
- Williams v. Maryland, 519 U.S. 408 (U.S. 1997) (orders to reenter a vehicle during traffic stop limited intrusion)