Phillip Anglin v. Lisa Draper et al.

Summary

The United States District Court for the Central District of Illinois granted Defendant Daniel J. Baker’s motion for summary judgment in Phillip Anglin’s Fourteenth Amendment excessive-force claim. The court concluded that the undisputed facts and video evidence showed no objectively unreasonable force and terminated Baker as a party, while reserving other dispositive motions for later consideration.

Holdings

1. Anglin's failure to respond to Baker's statement of undisputed material facts constituted an admission under the local rule, but did not automatically entitle Baker to judgment; Baker still had to demonstrate that he was entitled to judgment as a matter of law.
2. A pretrial detainee's excessive-force claim is analyzed under the Fourteenth Amendment's objective-unreasonableness standard, and Baker was entitled to summary judgment because the properly supported evidence, including video, showed no objectively unreasonable or violent use of force and Anglin failed to rebut that evidence with specific facts.

Questions Presented

1. Whether Baker was entitled to summary judgment on Anglin's Fourteenth Amendment excessive-force claim.
2. Whether Anglin's failure to respond to Baker's statement of undisputed material facts required judgment for Baker.
3. Whether the video evidence so contradicted Anglin's account that the court was required to view the facts as depicted by the video.

Disposition

other