Estate of Matthews v. City of Dearborn

Summary

The Sixth Circuit dismissed an interlocutory appeal from the denial of qualified immunity in a § 1983 excessive force case, holding that it lacked jurisdiction because the appeal was based on factual disputes rather than purely legal questions. The court emphasized that when a defendant challenges the district court's factual findings or credibility determinations—and does not concede the plaintiff's version of events or show that the record blatantly contradicts it—the appellate court cannot review the denial of qualified immunity. This case illustrates the limits of interlocutory jurisdiction over qualified immunity denials and the requirement that appeals must present legal, not factual, challenges.

Holdings

1. This court lacks jurisdiction over the interlocutory appeal because the appeal is based on factual disputes and not purely legal questions.

Questions Presented

1. Whether the court has jurisdiction over the interlocutory appeal from the denial of qualified immunity
2. Whether the district court erred in denying qualified immunity

Disposition

dismissed