Murphy v. Marlow

Summary

The Tenth Circuit vacated the district court’s denial of sovereign immunity for Deputy Jacob Marlow and the Kiowa County Sheriff’s Office and remanded for further proceedings. The court held that the district court erred by not determining whether the siren was used, correctly applied Rule 12(b)(1) standards, and did not commit clear error on the light‑mounting finding. The decision applies de novo review to statutory interpretation and clear‑error review to factual findings.