City of Escondido v. Emmons
2019 U.S. LEXIS 11, 139 S. Ct. 500, 202 L.Ed. 2d 455 (2019)
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Rule of Law:
For a right to be clearly established for the purposes of defeating qualified immunity, it must be defined with specificity, not at a high level of generality. In excessive force cases, existing precedent must squarely govern the specific facts at issue to put a reasonable officer on notice that their particular conduct is unlawful.
Facts:
- In April 2013, Escondido police responded to a domestic violence call from Maggie Emmons at her apartment and arrested her husband.
- A few weeks later, police received another 911 call reporting a domestic disturbance at the same apartment, with yelling and someone screaming for help.
- Officers Craig and Houchin responded, learned two children might be inside, and found that calls to the apartment went unanswered.
- At the scene, officers spoke with Maggie Emmons through a window but were denied entry to conduct a welfare check; they also heard an unidentified man's voice inside.
- Marty Emmons, Maggie's father, opened the apartment door and stepped outside.
- Officer Craig instructed Marty Emmons not to close the door, but Emmons closed it and attempted to brush past the officer.
- Officer Craig stopped Emmons, took him to the ground, and handcuffed him without using a weapon or striking him.
Procedural Posture:
- Marty Emmons sued Officer Craig and Sergeant Toth in the U.S. District Court for the Southern District of California under 42 U.S.C. § 1983 for excessive force.
- The District Court (trial court) granted summary judgment to the officers, holding they were entitled to qualified immunity.
- Emmons (as appellant) appealed the decision to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit reversed the trial court's grant of summary judgment, finding that the right to be free of excessive force was clearly established and that the case should proceed to trial.
- The City of Escondido and the officers (as petitioners) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does an officer violate clearly established law for qualified immunity purposes when, responding to a domestic disturbance call, they forcibly take a man to the ground after the man exits an apartment, closes the door against the officer's command, and attempts to brush past the officer?
Opinions:
Majority - Per Curiam
No. An officer does not violate clearly established law in these circumstances because the right against excessive force was not defined with enough specificity to put the officer on notice that this particular conduct was unlawful. The doctrine of qualified immunity protects officials from liability unless their conduct violates a statutory or constitutional right that was 'clearly established' at the time. The Ninth Circuit erred by defining the right at a high level of generality, stating only that the 'right to be free of excessive force was clearly established.' This is insufficient, especially in Fourth Amendment excessive force cases where the outcome is highly fact-dependent. The proper inquiry is whether existing precedent placed the unlawfulness of this specific action—taking down a non-compliant individual during a volatile domestic disturbance call—beyond debate. The precedent cited by the lower court involved passive resistance, which is factually distinct from this case where Marty Emmons physically defied an officer's command and tried to leave the immediate scene. Therefore, the lower court failed to conduct the required specific analysis to determine if Officer Craig's actions violated a right that was clearly established in this particular context.
Analysis:
This per curiam opinion strongly reinforces the Supreme Court's stringent application of the qualified immunity doctrine, particularly in excessive force cases. It serves as a direct command to lower courts to cease defining 'clearly established law' in broad, abstract terms. The decision makes it significantly more difficult for plaintiffs to overcome qualified immunity, as they must now identify a precedent with nearly identical facts to their own case. This raises the bar for civil rights claims against police to proceed to trial and signals the Court's continued expansion of protection for law enforcement officers in ambiguous situations.
