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Matthew Reid Hinsonv.R.A. Bias, Et Al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.16-14112
DecidedJune 14, 2019
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilCivil RightsConstitutional LawFourth AmendmentEighth AmendmentQualified ImmunityEvidenceReversal
Case Summary

After Matthew Hinson fatally stabbed a stranger at a Jacksonville pub, officers arrested him at a parking-garage exit. Hinson later sued under Section 1983, alleging that officers used excessive force during the arrest and were deliberately indifferent to medical needs. The officers’ sworn accounts and surveillance video showed Hinson refusing repeated commands, moving toward an officer, resisting efforts to handcuff him, and keeping his hands beneath his body after being taken to the ground. Officers used a takedown, several strikes to obtain his hands, and handcuffs; Hinson sustained abrasions but did not request medical care at the scene. The district court denied qualified immunity at summary judgment. The Eleventh Circuit vacated that ruling. It held that the admissible evidence did not materially contradict the officers’ account and that the force used to secure a suspect believed to be armed and resisting was not excessive under the Fourth Amendment. The record likewise did not show deliberate indifference under the Eighth Amendment. The officers were therefore entitled to qualified immunity.

Opinion

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