Estate of Williams v. Cline

Remand was required for Dist. Ct. to reconsider defendants-police officials’ motion for summary judgment in plaintiff-decedent’s section 1983 action, alleging that defendants used excessive force when arresting plaintiff, where, according to plaintiff, use of said force resulted in decedent’s death. Defendants argued that they were entitled to qualified immunity, and record showed that all 11 defendants played different roles in apprehending decedent during incident in which defendants believed that plaintiff was attempting armed robbery and was fleeing scene after being observed by defendants. While Dist. Ct., in denying defendants' summary motion, found that contested facts existed with respect to liability of all defendants, Dist. Ct. erred in failing to make individualized assessment of facts with respect to each defendant, especially where each defendant had different degree of contact with plaintiff and had different assigned responsibilities with respect to plaintiff’s apprehension and investigation of plaintiff’s alleged armed robbery.