Elmer Graham v. Iris Cawthorn

Summary

The court reversed the denial of Graham’s motion and remanded because collateral estoppel barred relitigation of the probable-cause, excessive-force, and policy-or-custom issues resolved in the prior federal judgment. The court also held that Graham was entitled to qualified immunity on Cawthorn’s Arkansas constitutional remonstration claim because the asserted right was not clearly established when the arrest occurred. The official-capacity failure-to-train and failure-to-supervise claims could not proceed without an underlying constitutional violation.