Swinfordv.Santos
The widow of a man shot by police brought federal and state claims after officers fired when he raised what reasonably appeared to be a real gun and pointed it toward them. At the pleading stage, the district court considered body-camera footage under the incorporation-by-reference doctrine and dismissed the claims. The Eleventh Circuit held that the footage was central to the complaint, its authenticity was undisputed, and it contradicted allegations that the officers lacked an immediate threat. The officers’ use of deadly force was objectively reasonable and, at minimum, protected by qualified immunity. Denial of amendment and reconsideration was also affirmed.
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