Eric Darden v. City of Fort Worth, Texas

Court of Appeals for the Fifth Circuit
880 F.3d 722 (2018)

ELI5:

Rule of Law:

When genuine disputes of material fact exist regarding whether an arrestee was actively resisting, police officers are not entitled to qualified immunity at the summary judgment stage for using force that would be unconstitutional against a non-resisting individual. Furthermore, the eggshell skull rule applies in § 1983 excessive force cases, meaning a victim's pre-existing medical conditions do not sever the causal link between the officers' use of force and the resulting injury or death.

Facts:

Fort Worth police officers obtained a no-knock warrant to search a private residence for evidence of cocaine sales.
On May 16, 2013, a heavily armed police team executed the warrant.
Upon entry, Jermaine Darden, a 340-pound man, was kneeling on a couch and immediately raised his hands.
Officer Snow ripped Darden's shirt off and, according to eyewitnesses, threw him to the ground, though Darden made no threatening gestures and did not resist.
Officer Romero then entered and, according to witnesses, choked Darden and repeatedly punched and kicked him in the face.
Officer Snow deployed his Taser on Darden twice.
Throughout the encounter, eyewitnesses and Darden himself repeatedly yelled that he had asthma and could not breathe.
Several officers forced Darden into a prone position, pressed his face into the ground, and handcuffed his hands behind his back, at which point Darden suffered a fatal heart attack.

Procedural Posture:

The administrator of Jermaine Darden's estate filed a lawsuit under 42 U.S.C. § 1983 against Officers Snow, Romero, and the City of Fort Worth in the U.S. District Court.
The defendants moved for summary judgment, with the officers asserting the defense of qualified immunity.
The district court granted summary judgment in favor of all defendants, holding that the officers were entitled to qualified immunity because they had not violated clearly established law.
The plaintiff, Darden's estate, appealed the dismissal to the U.S. Court of Appeals for the Fifth Circuit.

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Issue:

Do police officers who use significant force—including tasers, strikes, and positional restraint—on an obese arrestee with a medical condition violate a clearly established Fourth Amendment right, thus precluding qualified immunity, when there is a genuine factual dispute as to whether the arrestee was actively resisting or merely struggling to breathe?

Opinions:

Majority - Prado, J.

Yes, police officers who use such force under these circumstances may violate a clearly established Fourth Amendment right, precluding qualified immunity at the summary judgment stage. The court reversed the grant of summary judgment, finding that genuine disputes of material fact existed. First, the court rejected the district court's causation analysis by applying the 'eggshell skull' rule, holding that Darden's pre-existing health conditions did not break the causal chain between the officers' force and his death. Second, applying the Graham v. Connor factors, the court found that while the crime was serious, there was a key factual dispute about whether Darden posed a threat or was actively resisting arrest. Unlike in Scott v. Harris, the available video footage was ambiguous and did not 'blatantly contradict' the eyewitness testimony that Darden was compliant and struggling to breathe. Because prior case law had clearly established that tasing, striking, or choking a non-resisting suspect constitutes excessive force, a jury could find the officers' actions were objectively unreasonable. Therefore, Officers Snow and Romero were not entitled to qualified immunity at this stage.

Analysis:

This decision reinforces the principle that qualified immunity is not an impenetrable shield for law enforcement at the summary judgment phase when critical facts are in dispute. It underscores the high evidentiary standard set by Scott v. Harris, clarifying that video evidence must be truly unambiguous to override contrary witness testimony. The ruling also formally applies the common law 'eggshell skull' doctrine to § 1983 excessive force claims in the Fifth Circuit, preventing defendants from using a victim's pre-existing vulnerabilities as a defense to causation. This precedent makes it more difficult for officers to obtain early dismissal in cases involving disputed accounts of resistance and the use of significant force.

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