Matusak v. Daminski

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.

Holdings

1. 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.
2. 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.
3. 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.

Questions Presented

1. 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.
2. 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.
3. Whether the district court erred by using special interrogatories asking whether Matusak was resisting, rather than distinguishing between active and passive resistance.

Disposition

affirmed