Summary
This Eighth Circuit per curiam opinion addresses an interlocutory appeal by a police officer and the City of Minneapolis challenging a district court's denial of qualified immunity following a fatal police shooting. The appellate court concludes it lacks jurisdiction to review the appeal because doing so would require re-weighing disputed facts that are not blatantly contradicted by the body camera footage. Consequently, the court dismisses the appeal without reaching the merits of the qualified immunity or municipal liability claims.
Topics
Practice areas
Questions Presented
- Whether this court has jurisdiction to review the district court's factual assumptions in an interlocutory appeal concerning qualified immunity.
Holdings
- The Eighth Circuit lacks jurisdiction to review the district court's factual assumptions on an interlocutory appeal and therefore dismisses the appeal.
Key quotations
“The body‑worn‑camera videos provide dim, unclear images of the incident’s critical moments.” (5)
“We lack jurisdiction to address whether the evidence is sufficient to support the allegations in the complaint, the appeal must be dismissed.” (5)
Factual background
A Minneapolis SWAT team entered an apartment searching for a murder suspect. Amir Locke, the suspect's cousin, was asleep on a couch. After officers entered, Locke grabbed a handgun and began to lower it while complying with commands. Officer Hanneman ordered Locke to show his hands and then fired three shots, killing Locke within fifteen minutes.
Procedural history
The District Court for the District of Minnesota denied Officer Hanneman's motion for judgment on the pleadings. The plaintiffs moved to dismiss the appeal for lack of jurisdiction. The Eighth Circuit dismissed the appeal, finding it lacked jurisdiction to review the district court's factual assumptions.