Scotia v. Kansas City Board of Police Commissioners

Summary

The Eighth Circuit vacated and remanded a district court order denying Officer William Thompson qualified immunity and official immunity in an excessive-force and wrongful-death action arising from the shooting of Ryan Stokes. The court held that the district court had not adequately identified the plaintiff-friendly facts or analyzed whether Thompson violated clearly established law. It also held that the court improperly treated qualified immunity and Missouri official immunity as interchangeable inquiries.

Holdings

1. When denying qualified immunity at summary judgment, the district court must specifically identify the plaintiff-friendly version of the disputed facts and determine whether, in light of the information actually available to the officer, the officer violated clearly established law. A generalized excessive-force right and the existence of factual disputes are insufficient by themselves.
2. A district court is not required to decide whether the officer violated the Constitution before deciding whether the asserted right was clearly established.
3. Missouri official immunity and federal qualified immunity are distinct inquiries, and a district court must separately determine whether the facts would allow a reasonable jury to find that the officer acted with malice or in bad faith.
4. The denial of qualified immunity and official immunity, as threshold immunity issues, is subject to interlocutory appellate review.

Questions Presented

1. Whether the district court adequately analyzed Thompson's entitlement to qualified immunity when it denied summary judgment based on a general right to be free from excessive force and unresolved factual disputes.
2. Whether the district court properly analyzed Thompson's entitlement to Missouri official immunity, rather than treating that inquiry as interchangeable with qualified immunity.
3. Whether the denial of qualified and official immunity could be reviewed on interlocutory appeal.

Disposition

vacated