Chaney-Snell v. Young, No. 22-1990 (6th Cir. 2024)
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The case involves Kamel Chaney-Snell, who was arrested by Deputy Andrew Young and Officer Andrew Teichow during a search of his girlfriend's house. Chaney-Snell claimed that after he peacefully surrendered, Young punched him in the face, and one of the officers kneed him in the back and dragged him across the floor. He sued Young and Teichow under 42 U.S.C. § 1983, alleging excessive force and failure to intervene. The district court denied qualified immunity to both officers.
The officers' appeals raised three questions. First, whether the court must accept Chaney-Snell’s claim that Young gratuitously punched him despite Chaney-Snell’s guilty plea for attempting to resist arrest. The Sixth Circuit found that it lacked jurisdiction over Young’s Heck claim, and his judicial-estoppel claim failed on the merits.
Second, whether the Fourth Amendment allows officers to use unnecessary force on arrestees if the force qualifies as “de minimis”. The court held that gratuitous force violates the Fourth Amendment even if the force is minor and causes no serious injury.
Finally, whether Chaney-Snell established a “failure to intervene” theory of liability. The court found that qualified immunity protects the officers from Chaney-Snell’s failure-to-intervene claims.
The Sixth Circuit affirmed in part, reversed in part, and dismissed in part for lack of jurisdiction.
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