Samuel Lee Patterson v. M.G. Wolfe, et al.

Summary

The document is an Order, Memorandum Opinion, and Recommendation addressing motions in Samuel Lee Patterson’s 42 U.S.C. § 1983 action arising from a March 2021 arrest in North Carolina. The magistrate judge denies the motion to seal, recommends denying Patterson’s motion to amend, and recommends granting the defendants’ motions for summary judgment. The opinion discusses Heck v. Humphrey, excessive force, bystander liability, deliberate indifference to medical needs, qualified immunity, and official-capacity claims.

Holdings

1. Leave to amend was properly denied because the proposed amendment, filed more than two years after the action began and after discovery and summary-judgment briefing, would cause undue delay and prejudice.
2. To the extent plaintiff sought to undermine his convictions by challenging the lawfulness of the vehicle pursuit or arrest, those claims were barred by Heck v. Humphrey because the convictions had not been reversed, expunged, declared invalid, or called into question by habeas relief.
3. Summary judgment was warranted on the excessive-force claims because the record and video evidence showed no genuine dispute that the force used to restrain plaintiff during the arrest was objectively unreasonable, and the video contradicted plaintiff's allegation that force continued after he was handcuffed.
4. Defendants were entitled to summary judgment on plaintiff's failure-to-intervene claims because plaintiff failed to establish an underlying constitutional violation and the record did not show that either defendant had a reasonable opportunity to prevent the alleged strike.
5. Plaintiff failed to establish deliberate indifference because he received prompt and adequate medical care, and the alleged misleading statement by Wolfe did not delay or deny treatment.
6. Wolfe was entitled to qualified immunity because plaintiff failed to demonstrate a constitutional violation.
7. Plaintiff's official-capacity claim against Wolfe failed because there was no underlying constitutional violation supporting municipal liability.
8. The motion to seal was denied because defendant did not show a compelling governmental interest narrowly tailored to overcome the First Amendment right of access to judicial records.

Questions Presented

1. Whether plaintiff should be permitted to file a second amended complaint after discovery closed and summary-judgment motions were briefed.
2. Whether plaintiff's claims challenging the lawfulness of the vehicle pursuit and arrest were barred by Heck v. Humphrey because his convictions remained valid.
3. Whether the evidence created a genuine dispute that Defendant Wolfe used excessive force during plaintiff's restraint and arrest.
4. Whether defendants were liable under a bystander-liability theory for failing to intervene in an alleged use of excessive force.
5. Whether Defendant Wolfe was deliberately indifferent to plaintiff's serious medical needs by allegedly providing misleading information to emergency personnel.
6. Whether Defendant Wolfe was entitled to qualified immunity.
7. Whether plaintiff's official-capacity claim against Defendant Wolfe could proceed without an underlying constitutional violation.
8. Whether Defendant Laws used excessive force after plaintiff was handcuffed and restrained.
9. Whether Defendant Wolfe's medical records should be sealed under the First Amendment right of access to judicial records.

Disposition

other