Chaney-Snell v. Young
| Docket Number | 22-1990,22-1992 |
| Decision Date | 15 April 2024 |
| Citation | 98 F.4th 699 |
| Parties | Kamel CHANEY-SNELL, Plaintiff-Appellee, v. Andrew YOUNG (22-1992); Andrew Teichow (22-1990), Defendants-Appellants. |
| Court | U.S. Court of Appeals — Sixth Circuit |
Appeal from the United States District Court for the Eastern District of Michigan at Detroit. No. 2:20-cv-13064—Nancy G. Edmunds, District Judge.
ARGUED: Todd J. Shoudy, FLETCHER FEALKO SHOUDY & FRANCIS, PC, Port Huron, Michigan, for Appellant Young. Kevin J. Campbell, CUMMINGS, MCCLOREY, DAVIS & ACHO, PLC, Livonia, Michigan, for Appellant Teichow. Shawn C. Cabot, CHRISTOPHER TRAINOR & ASSOCIATES, White Lake, Michigan, for Appellee. ON BRIEF: Todd J. Shoudy, FLETCHER FEALKO SHOUDY & FRANCIS, PC, Port Huron, Michigan, for Appellant Young. Kevin J. Campbell, CUMMINGS, MCCLOREY, DAVIS & ACHO, PLC, Livonia, Michigan, for Appellant Teichow. Shawn C. Cabot, CHRISTOPHER TRAINOR & ASSOCIATES, White Lake, Michigan, for Appellee.
Before: WHITE, NALBANDIAN, and MURPHY, Circuit Judges.
Deputy Andrew Young and Officer Andrew Teichow arrested Kamel Chaney-Snell during a search of his girlfriend's house. Chaney-Snell pleaded guilty to attempting to resist their arrest. But he now claims 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. Chaney-Snell sued Young and Teichow under 42 U.S.C. § 1983, alleging excessive-force and failure-to-intervene claims. The district court denied qualified immunity to both officers.
Their appeals raise three questions. Question One: Must we accept Chaney-Snell's claim that Young gratuitously punched him despite Chaney-Snell's guilty plea for attempting to resist arrest? Young answers "no" on the ground that Chaney-Snell's claim conflicts with his conviction. See Heck v. Humphrey, 512 U.S. 477, 486-87, 114 S.Ct. 2364, 129 L.Ed.2d 383 (1994). At the least, Young argues, judicial estoppel bars Chaney-Snell's claim because it also conflicts with his admissions at his plea hearing. But we lack jurisdiction over Young's Heck claim, and his judicial-estoppel claim fails on the merits.
Question Two: Does the Fourth Amendment allow officers to use unnecessary force on arrestees if the force qualifies as "de minimis"? Young and Teichow concede that, under Chaney-Snell's allegations, one of them gratuitously kneed him in the back and dragged him on the floor. They nevertheless argue that this force falls below the minimum level required for an excessive-force claim. But our cases have long held that gratuitous force violates the Fourth Amendment even if the force is minor and causes no serious injury. And these cases comport with the common-law backdrop against which the Fourth and Fourteenth Amendments were enacted.
Question Three: Has Chaney-Snell established a "failure to intervene" theory of liability? Chaney-Snell seeks to hold the officer who did not employ the challenged force liable for failing to prevent it. Even under his allegations, however, this officer did not have a realistic opportunity to stop each of the quick and discrete actions. And while the district court decided to treat all of the actions as a single continuous use of force, our caselaw does not clearly establish that decision. Qualified immunity thus protects the officers from Chaney-Snell's failure-to-intervene claims.
All told, we affirm in part, reverse in part, and dismiss in part for lack of jurisdiction.
Chaney-Snell often stayed at his girlfriend's home in Port Huron, Michigan. In 2018, he began selling drugs from this home without his girlfriend's permission. These drug deals drew the attention of a drug task force operating in St. Clair County. A confidential informant working with the task force bought drugs from Chaney-Snell at his girlfriend's home in early 2019. That February, a task-force officer obtained a warrant to search her house.
The task force executed the warrant on the evening of February 6. Deputy Young and Officer Teichow, two task-force members, participated in this search. The Port Huron Police Department had assigned Teichow to the task force, and the St. Clair County Sheriff's Department had assigned Young.
At the time of the search, Chaney-Snell was at his girlfriend's home alone because she had gone to work. The parties tell drastically different stories of how Young and Teichow arrested Chaney-Snell while securing this home.
We begin with the officers' account. According to Young and Teichow, an officer knocked on the front door and announced their presence. Nobody answered. So another officer rammed open the door. Young entered first, followed by Teichow. They encountered a second locked door because the homeowner had split the home into two units. Young kicked in the door. Officers then flooded the house shouting "sheriff's department, search warrant, get on the ground." Young Dep., R.30-7, PageID 726.
As Young and Teichow made it to the dining area, they spotted Chaney-Snell in the living room. The officers screamed for him to "get on the ground," but he fled to a bedroom. Teichow Dep., R.30-6, PageID 697; Young Dep., R.30-7, PageID 727. The officers pursued him.
When they entered the bedroom, they saw Chaney-Snell concealing himself in a closet. Chaney-Snell had his back to the officers, so they told him to show his hands. He did not comply. Young ran toward the closet while holstering his firearm. He pushed Chaney-Snell into the wall and onto the ground to handcuff him. When using this force, Young placed one hand on Chaney-Snell's back and the other on his face. Chaney-Snell hit the ground on the left side of his face and stomach. Young fell on top of him. But Chaney-Snell continued to struggle. Young struck Chaney-Snell with his knee a few times to get Chaney-Snell to place his arms behind his back. The officers then handcuffed him. Young patted Chaney-Snell down, and the officers walked him to a bed to sit on.
Chaney-Snell recalls things differently. He did not hear the officers announce their presence because he was in a bedroom listening to "loud" music on his headphones. Chaney-Snell Dep., R.30-4, PageID 568. But Chaney-Snell thought he heard a "bang" when Young kicked open the second door. Id. The noise led Chaney-Snell to take off his headphones and stand up.
At that time, two officers ran into the bedroom and shouted "show me your hands." Id., PageID 572. Chaney-Snell immediately raised his hands. Yet he says that an officer punched him in the left eye without warning. So Chaney-Snell covered his face and failed to comply with additional requests to raise his hands. But he eventually put them up again. The same officer then sucker punched him a second time in the same spot. Chaney-Snell fell to the ground. He recalls putting up no resistance as the officers handcuffed him. Right after they restrained him, Chaney-Snell could feel an officer kneeing him in the back using his full weight. An officer next dragged him across the bedroom floor by his ankles. The officers picked Chaney-Snell up, strip-searched him, and put him on the bed.
Once Chaney-Snell made it to the bed, the parties' stories reconverge. The officers acknowledged that Chaney-Snell had an injury on his left eye and a rug burn on his right shoulder. Teichow added that Chaney-Snell said that "he was having a hard time breathing" and asked for his asthma inhaler. Teichow Dep., R.30-6, PageID 702. Another officer gave Chaney-Snell "three puffs" from this inhaler. Chaney-Snell Dep., R.30-4, PageID 576. Paramedics checked on him, and an officer drove him to jail. A jail nurse sent Chaney-Snell to the hospital.
The hospital took several CT scans. Scans of Chaney-Snell's back and head showed no injuries, but an eye scan revealed what a doctor diagnosed as a "minimal nondisplaced blowout fracture" to his left orbital bones. Records, R.35-7, PageID 1032. The doctor recommended that Chaney-Snell take Tylenol for any pain and discharged him.
Chaney-Snell's encounter with Young and Teichow produced both criminal and civil proceedings. The State of Michigan criminally charged Chaney-Snell with possessing cocaine and resisting the officers. Chaney-Snell entered a plea agreement. As part of the deal, he agreed to plead guilty to the drug count and to attempting to resist the officers. At his plea hearing, he conceded that Young and Teichow had given him "verbal commands to show them [his] hands" and that he had "failed to comply" with their "lawful" orders. Plea Tr., R.30-8, PageID 764-65. The state court accepted his plea. It sentenced him to six months' imprisonment.
With his criminal proceedings behind him, Chaney-Snell pursued this civil case under 42 U.S.C. § 1983. He sued Deputy Young and his employer (St. Clair County), as well as Officer Teichow and his employer (the City of Port Huron). Chaney-Snell could not identify which officer did what. But he alleged that one officer used excessive force and that the other failed to intervene to stop this force, both in violation of the Fourth Amendment. He also asserted claims against St. Clair County and the City of Port Huron under Monell v. Department of Social Services, 436 U.S. 658, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978).
All defendants moved for summary judgment. Discovery identified Young as the only officer who could have punched Chaney-Snell. But Young asked the district court to reject this allegation. He argued that the "Heck doctrine" barred the claim because it contradicted Chaney-Snell's conviction. See Heck, 512 U.S. at 486-87, 114 S.Ct. 2364. He also argued that judicial estoppel barred the claim because it conflicted with Chaney-Snell's admissions in open court. The district court disagreed. See Chaney-Snell v. Young, 2022 WL 4667942, at *3-4 (E.D. Mich. Sept. 30, 2022).
The district court also rejected Young's and Teichow's requests for qualified immunity. It held that Young would have...
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