Supreme Court of the United States
City of Escondido, California v. Marty Emmons.
January 7, 2019586 U.S. 38
Summary
In a per curiam opinion, the Supreme Court reversed the Ninth Circuit's reinstatement of an excessive force claim against Sergeant Toth, who used no force, and vacated the denial of qualified immunity to Officer Craig because the court below defined the clearly established right only at a high level of generality. The Court reiterated that qualified immunity turns on whether existing precedent placed the lawfulness of the officer's specific conduct beyond debate, not on a generalized right to be free of excessive force. It remanded so the Court of Appeals could perform the required clearly-established-law analysis as to Officer Craig's takedown of Marty Emmons.
Holding
- Whether the Ninth Circuit erred in reinstating the excessive force claim against Sergeant Toth.. Yes. The Ninth Circuit's unexplained reinstatement of the excessive force claim against Sergeant Toth was erroneous, because the record showed that only Officer Craig used any force and Emmons failed to identify contrary evidence.
- Whether the Ninth Circuit properly denied Officer Craig qualified immunity by defining the clearly established right at a high level of generality.. No. The Court of Appeals' formulation—that the right to be free of excessive force was clearly established—was far too general; it failed to analyze whether clearly established law prohibited Officer Craig from stopping and taking down Marty Emmons in these circumstances, so the judgment as to Craig was vacated and the case remanded for the required analysis.
Docket 17-1660