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Watkinsv.Davis

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.23-13616
Decided2025-09-25
ReporterNo. 23-13616 (11th Cir. 2025)
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
Eleventh CircuitSection 1983Excessive ForcePolice ShootingQualified ImmunityFourth AmendmentSummary Judgment
Case Summary

Tammy Watkins sued two officers under Section 1983 after they approached her at night without identifying themselves, fired at her vehicle as she attempted to leave, detained her, and seized her SUV. The district court denied the officers qualified immunity at summary judgment. Viewing the disputed evidence in Watkins’s favor, the Eleventh Circuit held that the officers lacked even arguable reasonable suspicion for the stop, that a jury could find their use of deadly force objectively unreasonable, and that controlling precedent clearly prohibited shooting a non-dangerous person who had not used or threatened to use a vehicle as a weapon. It also held that the warrantless seizure of Watkins’s SUV was unsupported by exigent circumstances and violated clearly established law. The court affirmed the denial of qualified immunity and remanded for further proceedings.

Opinion

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