- The 4th US Circuit Court of Appeals will allow a woman to move forward with her excessive-force lawsuit against three Randolph County sheriff's deputies.
- A unanimous Appeals Court panel rejected the deputies' argument that qualified immunity shielded them from legal liability.
- Appellate judges noted the “obvious illegality” of the “outrageous conduct” alleged in the suit. Plaintiff Ka'Lah Martin accused deputies of breaking her car windows and pulling her from the vehicle to arrest her during a traffic stop.
The 4th US Circuit Court of Appeals will allow a woman to proceed with her federal excessive-force lawsuit against three Randolph County sheriff’s deputies. Appellate judges ruled Thursday against granting the deputies immunity from the suit.
The court’s opinion noted the “obvious illegality” of the “outrageous conduct” alleged in the suit.
Ka’Lah Martin’s complaint stemmed from a February 2019 traffic stop “that turned violent and culminated in her arrest,” wrote Judge Robert Bruce King for the unanimous 4th Circuit panel.
Martin was driving a $600 car that “had some issues,” in King’s words. She could open neither the front doors nor windows. When a Randolph County sheriff’s deputy attempted to stop Martin for failing to display a registration plate, she slowed her speed from 65 miles per hour to 30 mph and turned on her hazard lights. Martin drove for nearly six miles before turning off the road.
By that time, other deputies arrived on the scene. They broke the front driver’s-side and passenger-side windows and pulled Martin from the car before pushing her to the ground and arresting her.
Martin filed suit in November 2021. Among her claims were excessive-force violations by deputies Travis Short, Kyle Gabby, and Jeremiah Harrelson. Each deputy claimed qualified immunity. The trial court rejected that defense and ruled that the excessive-force claims should proceed to trial.
“[W]e underscore that the appellants present the district court’s factual recitation in a way that actually favors them over plaintiff Martin in several respects,” King wrote. “For example, the appellants would have us rule that their use of force was reasonable based on the evidence that Martin continued to drive for 5.7 miles after appellant Short initiated his patrol car’s emergency lights and that Martin needed no more than a band-aid, Ibuprofen, and muscle relaxers for injuries sustained during her arrest.”
“Concomitantly, the appellants would have us diminish and outright disregard evidence tending to refute any threat that otherwise might be inferred from Martin’s continued driving (such as the evidence that Martin slowed her vehicle significantly and turned on the vehicle’s hazard lights), as well as evidence suggesting that any lack of more serious injuries was simply a matter of luck (i.e., the evidence that the appellants busted out the driver’s side window, forcibly pulled Martin through the broken window by her hair and arm, and then placed her face down on the roadway),” King added.
“At bottom, when we view the facts in the light that is truly most favorable to plaintiff Martin, we cannot conclude either that the appellants did not contravene her Fourth Amendment right against an unreasonable seizure or that the right was not clearly established at the time of her arrest,” King concluded.
“Indeed, we are convinced that — when, as Martin alleges happened, the appellants violently busted out the windows of her vehicle and yanked her through the broken driver’s side window by her hair and arm — every reasonable officer would have understood that what he was doing was unlawful, whether by then-existing precedent or by the otherwise obvious illegality of that outrageous conduct,” King wrote.
Chief Judge Albert Diaz and Judge Harvie Wilkinson joined King’s opinion.