Summary
The United States Court of Appeals for the Second Circuit affirmed the district court’s grant of judgment as a matter of law to Monroe County Sheriff’s Office officers on qualified-immunity grounds. Although a jury found that two officers used excessive force during Christopher Matusak’s arrest, the court held that no clearly established law prohibited the force used against a resisting arrestee whom the officers reasonably, though mistakenly, believed posed a threat to officer safety.
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Practice areas
Questions Presented
- Whether the district court properly granted judgment as a matter of law to Murphy and Unterborn on qualified-immunity grounds after the jury found that they used excessive force.
- Whether clearly established law as of February 1, 2018, prohibited officers from using fist strikes, knee strikes, and a taser against an arrestee who was resisting efforts to handcuff him and whom the officers reasonably, but mistakenly, believed posed a threat to officer safety.
- Whether the district court erred by using special interrogatories asking whether Matusak was resisting, rather than distinguishing between active and passive resistance.
Holdings
- Murphy and Unterborn were entitled to qualified immunity because no clearly established law prohibited their use of fist strikes, knee strikes, and a taser against Matusak while he was resisting arrest and they reasonably, though mistakenly, believed he posed a threat to officer safety.
- The district court did not err by asking whether Matusak was resisting rather than requiring the jury to classify his resistance as active or passive, because Second Circuit law had not clearly distinguished those categories for qualified-immunity purposes as of the date of the arrest.
- An officer may receive qualified immunity based on a reasonable mistake of fact, including a reasonable but mistaken belief that an arrestee posed a threat to officer safety.
Key quotations
“We hold that Murphy and Unterborn are entitled to qualified immunity because no clearly established law prohibited the force the officers employed, where Matusak was resisting arrest and the officers reasonably, but mistakenly, believed he posed a threat to officer safety.” (at 2-3)
“Thus, by the time of Matusak’s arrest on February 1, 2018, it was clearly established that officers may not use significant force against arrestees who are compliant or non-resistant and non-threatening.” (at 27-28)
“Here, no clearly established law prohibited the officers’ use of fist and knee strikes and a taser where Matusak was resisting arrest and the officers reasonably, but mistakenly, believed he posed a threat to officer safety.” (at 42-43)
Factual background
On February 1, 2018, Christopher Matusak fled from Deputy Matthew Daminski in Scottsville, New York, after Daminski followed him based on observed traffic violations. Daminski and responding officers used fist and knee strikes, pepper spray, and a taser before handcuffing Matusak. The jury found that Murphy and Unterborn used excessive force, but also found that Matusak was resisting the officers' attempts to pull out his arms and that each officer reasonably believed Matusak posed a threat to officer safety, although he did not actually pose such a threat.
Procedural history
Matusak brought a 42 U.S.C. § 1983 action alleging that three Monroe County Sheriff's Office officers used excessive force during his arrest. After denying defendants' initial motion to dismiss as moot when it granted Matusak leave to amend, the district court conducted a jury trial. The jury found in favor of Daminski, but found that Murphy and Unterborn used excessive force and awarded $200,000 in compensatory damages. Based on special interrogatories finding that Matusak resisted arrest and that Murphy and Unterborn reasonably believed he posed a threat to officer safety, the district court granted judgment as a matter of law to those officers on qualified-immunity grounds. The Second Circuit affirmed.