Judge Andre Mathis, who was nominated by President Biden to the Sixth Circuit court of appeals, wrote a unanimous decision, which was joined by Biden judge Rachel Bloomekatz, which allowed a claim of excessive use of force by a Detroit police officer to proceed. The ruling upheld a lower court decision that rejected the officer’s defense of qualified immunity. The October 2024 decision was in Jackson-Gibson v Beasley.
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What happened in this case?
Detroit resident Lamonte Jackson-Gibson, along with his girlfriend Toriel Dixon and several others, was celebrating his birthday on a Friday night. They went to the Greektown area and stopped on a public sidewalk to listen to some street musicians. For no expressed reason, Detroit police Sergeant Reginald Beasley and several other officers approached the group and Beasley asked them to “move along.” Jackson-Gibson asked why, and a disagreement took place, with no violence. At one point, Beasley grabbed Jackson-Gibson’s wrist and started to handcuff him, but a friend led him away.
Beasley then pointed a taser at the group and again directed them to move along. Attempting to defuse the situation, Dixon wrapped her arms around her boyfriend. Without any warning, Beasley then tased Jackson-Gibson in the back for five seconds. He “fell to the ground screaming” and was arrested for disturbing the peace and resisting a police officer. A jury acquitted him of all charges.
Jackson-Gibson then filed a federal lawsuit, charging Beasley with use of excessive force in violation of his constitutional rights. Beasley moved for summary judgment, asserting that he was entitled to qualified immunity on the use of excessive force claim. The district court denied Beasley’s motion, and he then brought the case to the Sixth Circuit.
How did Judges Mathis, Bloomekatz and the Sixth Circuit rule and why is it important?
Judge Mathis wrote a unanimous opinion, joined by Judge Bloomekatz, that upheld the lower court ruling and rejected Beasley’s defense of qualified immunity so that the case can go forward. Initially, he explained that in accord with past precedent, the question of whether Beasley has used excessive force had to be determined using an “objective reasonableness” standard. Based on that standard and the facts alleged in the complaint, he went on, a “reasonable jury” could well conclude that Beasley’s actions were not justified because the suspect was not “actively resisting or evading arrest,” the crimes charged were not severe, and there was no “immediate threat” to Beasley or others, and that Beasley therefore “violated Jackson-Gibson’s Fourth Amendment right to be free from excessive force” when he was tased.
Judge Mathis then went on to consider whether this constitutional right was “clearly established” at the time of the incident. Based on past precedent, he concluded that it clearly was. The lower court was accordingly correct, he wrote, in determining that qualified immunity did not apply to Beasley in this case.
The decision of Judges Mathis and Bloomekatz is obviously important to Lamonte Jackson-Gibson, who can now proceed to seek damages and justice for the excessive force used against him by Sgt. Beasley. The ruling will likely also be useful in other cases concerning alleged use of excessive force by police, particularly in the Sixth Circuit, which includes Michigan, Ohio, Kentucky, and Tennessee. In addition, the decision serves as a reminder of the importance of promptly confirming fair-minded judges to our federal courts.