Seventh Circuit Grants Qualified Immunity to Police Officers
In Johnson v. Edwards, an arrestee sued four police officers alleging they violated his constitutional rights after he was arrested for disorderly conduct.
Johnson was arrested after he attempted to enter an area that had been taped off for police investigation of a crime scene. When the police officers ordered Johnson to leave the area, he became agitated and began to yell at the officers. Johnson refused to leave and the officers arrested Johnson, put him in the squad car, and drove him to the police station. Johnson had refused to wear his seatbelt on the drive there. On the way there, Johnson asked the officer to slow down. The officer quickly slowed the car down to stop at a red light which caused Johnson to lurch forward and hit his head on the divider. Two minutes later, when they arrived at the station, the officers realized Johnson had been knocked unconscious. He was taken to the hospital where he was diagnosed and treated for a cut lip.
Johnson was charged with disorderly conduct for failing to obey a police officer. After the charges were dropped, he sued the officers involved in his arrest, claiming the following constitutional violations: (1) false arrest in violation of the Fourth Amendment; (2) state-created danger in violation of the Fourteenth Amendment’s Due Process Clause; (3) excessive use of force for the “rough ride” to the station; (4) failure to provide adequate medical care. Johnson also brought a claim for malicious prosecution. The district court ruled in favor of the police officers, finding they were immune from Johnson’s claims based on qualified immunity.
On appeal, the Seventh Circuit Court of Appeals upheld the ruling in favor of the officers. The Seventh Circuit found that Johnson had not established a violation of his constitutional rights because: (1) the officers had probable cause to arrest Johnson for engaging in disorderly conduct when he refused to leave the crime scene; (2) the officers had not placed Johnson in a position of danger, or violated an established constitutional right, by allowing him to ride to the station without a seatbelt on; (3) the facts did not support a finding that the ride to the station constituted an excessive use of force; and (4) the officers had called the paramedics as soon as they realized Johnson was hurt, so Johnson could not establish that they acted unreasonably. Because Johnson failed to establish a violation of a constitutional right, the Seventh Circuit found the officers were entitled to qualified immunity for their actions.
As to Johnson’s malicious prosecution claim, the Court found that the officers had probable cause to arrest Johnson for disorderly conduct and dismissed this claim.
Post Authored by Alexis Carter
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