Eric Westry v. Connor Ahearn, Adrian Sanchez, Anthony Anderson, Anthony Quicquaro, Jason Krauter, and Raymond Rose

Summary

The United States District Court for the District of Connecticut rules on defendants’ motion for summary judgment in Eric Westry’s 42 U.S.C. § 1983 action. The opinion grants summary judgment on the deliberate-indifference-to-medical-needs claim, denies summary judgment on the excessive-force claim, and addresses the Fourth Amendment unlawful-entry claim involving entry into Westry’s apartment.

Holdings

1. Summary judgment was proper for Officers Quicquaro, Sanchez, and Anderson because the record did not create a genuine issue that the temporary denial of Westry's medication caused substantial harm or worsened his underlying condition.
2. Summary judgment was denied on Westry's excessive-force claim because, viewing the evidence favorably to him, a reasonable jury could find that the officers' force against a compliant, nonresisting arrestee was objectively unreasonable.
3. Officer Ahearn was not entitled to summary judgment because the record did not establish exigent circumstances justifying his warrantless entry into Westry's apartment.
4. Officers Krauter and Rose were not entitled to qualified immunity at summary judgment because, accepting Westry's allegations, it was objectively unreasonable for officers to believe that forcibly wrenching the arms of a compliant arrestee, causing pain, was lawful.
5. Officer Ahearn was not entitled to qualified immunity because it was not objectively reasonable for him to believe that exigent circumstances justified entering Westry's apartment without a warrant.

Questions Presented

1. Whether the officers' failure to provide Westry's blood-pressure medication during pretrial detention constituted deliberate indifference to a serious medical need under the Fourteenth Amendment.
2. Whether the evidence created a genuine dispute of material fact as to whether Officers Krauter and Rose used objectively unreasonable excessive force during Westry's arrest.
3. Whether Officer Ahearn's warrantless entry into Westry's apartment was justified by exigent circumstances under the Fourth Amendment.
4. Whether Officers Krauter, Rose, and Ahearn were entitled to qualified immunity.

Disposition

other