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Keywords

liabilitydomestic violence
plaintiffappealtrialleasedomestic violence

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Escondido, Cal., City of, v. Emmons

Facts

The case arose from a domestic disturbance call made to the Escondido police by Maggie Emmons. Officers responded to the scene and arrested her husband for domestic violence. A subsequent call about another disturbance led to the officers forcibly apprehending Marty Emmons, Maggie's father, when he exited the apartment. He was arrested for resisting a police officer, and he later sued the officers for excessive force.

The record, viewed in the light most favorable to the plaintiff, shows the following. In April 2013, Escondido police received a 911 call from Maggie Emmons about a domestic violence incident at her apartment. Emmons lived at the apartment with her husband, her two children, and a roommate, Ametria Douglas. Officer Jake Houchin responded to the scene and eventually helped take a domestic violence report from Emmons about injuries caused by her husband. The officers arrested her husband. He was later released. A few weeks later, on May 27, 2013, at about 2:30 p.m., Escondido police received a 911 call about another possible domestic disturbance at Emmons`apartment. That 911 call came from Ametria Douglas`mother, Trina Douglas. Trina Douglas was not at the apartment, but she was on the phone with her daughter Ametria, who was at the apartment. Trina heard her daughter Ametria and Maggie Emmons yelling at each other and heard her daughter screaming for help. The call then disconnected, and Trina Douglas called 911.

Issue

Did the police officers violate clearly established law when they forcibly apprehended Marty Emmons at the scene of a reported domestic violence incident?

The question in this qualified immunity case is whether two police officers violated clearly established law when they forcibly apprehended a man at the scene of a reported domestic violence incident.

Rule

Qualified immunity protects government officials from liability unless they violated a clearly established statutory or constitutional right of which a reasonable person would have known.

Qualified immunity attaches when an officials conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.

Analysis

The Court determined that the Ninth Circuit erred by defining the clearly established right at a high level of generality, merely stating that the 'right to be free of excessive force' was clearly established. The Court emphasized that the right must be defined with specificity, particularly in excessive force cases, and that the Ninth Circuit failed to analyze whether the officers' actions were prohibited by existing law.

The Court of Appeals should have asked whether clearly established law prohibited the officers from stopping and taking down a man in these circumstances. Instead, the Court of Appeals defined the clearly established right at a high level of generality by saying only that the 'right to be free of excessive force' was clearly established. With the right defined at that high level of generality, the Court of Appeals then denied qualified immunity to the officers and remanded the case for trial.

Conclusion

The Supreme Court reversed the Ninth Circuit's judgment in part and vacated it in part, remanding the case for further proceedings consistent with its opinion.

The petition for certiorari is granted, the judgment of the Court of Appeals is reversed in part and vacated in part, and the case is remanded for further proceedings consistent with this opinion.

Who won?

The City of Escondido and the police officers prevailed because the Supreme Court found that the Ninth Circuit had misapplied the standard for qualified immunity.

The Court of Appeals failed to properly analyze whether clearly established law barred Officer Craig from stopping and taking down Marty Emmons in this manner as Emmons exited the apartment.

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