Young v. Stenger

Background

Lamar Young, representing himself, sued Sergeant James Stenger and Detectives Kelly Inabnett, Mellone, and Bledsoe under 42 U.S.C. § 1983. He alleges that the officers used excessive force during an October 29, 2020 interrogation at the West County Detention Center after he refused to wear a black mask for a photograph. Young alleges that Stenger, Mellone, and Bledsoe forced the mask onto him and that Stenger choked him. He alleges that Inabnett failed to intervene. He also brings a state-law negligence claim against Stenger and seeks damages, punitive damages, and declaratory and injunctive relief. The City of Antioch is also a defendant on a municipal-liability claim.

The incident was recorded. The video shows Young handcuffed while the officers attempted to place a mask and later a neck gaiter over his head. The parties disagree about whether Young resisted, whether he attempted to bite the officers or mask, how much force the officers used, and whether Stenger choked him. The court found that the video did not clearly resolve those disputes. Young reported mouth and throat pain and said he later sought medical and psychiatric assistance.

Summary-judgment rulings

Summary judgment is a decision without a trial that is appropriate only when no genuine dispute about an important fact exists and the moving party is entitled to judgment as a matter of law. The court held that material factual disputes prevented judgment for either side on the excessive-force claim. Those disputes included the amount of force used, Young’s degree of resistance, the danger he posed while handcuffed, the officers’ efforts to limit the force, and the extent of Young’s injuries.

The court applied the objective-reasonableness standard for excessive-force claims by a person detained after arrest but before arraignment. It concluded that a reasonable factfinder could find either that the officers used minimal force to take a photograph or that they used excessive force against a handcuffed detainee who posed little danger. Because deciding between those accounts would require judging credibility, the court denied both the defendants’ motion for summary judgment and Young’s cross-motion for summary judgment on the excessive-force claim against Stenger, Mellone, and Bledsoe.

The court also denied both sides’ motions on Young’s claim that Inabnett failed to intervene. It found factual questions about whether Inabnett meaningfully participated in the incident and whether he had an opportunity to stop excessive force. The court denied the defendants’ argument that the prior state-court ruling on Young’s motion to suppress barred this federal case through collateral estoppel, explaining that the issues and requested relief were not identical.

Qualified immunity

Qualified immunity can protect government officials from civil damages unless their conduct violated a constitutional right that was clearly established. The court found that, viewing the evidence in Young’s favor, the facts could support a constitutional violation and that factual disputes prevented a determination that the officers’ conduct was objectively reasonable. It therefore ruled that Stenger, Mellone, and Bledsoe were not entitled to qualified immunity on the excessive-force claim, and that Inabnett was not entitled to qualified immunity on the failure-to-intervene claim.

City, negligence, and punitive damages

The court determined that Young’s amended complaint stated a legally cognizable municipal-liability claim against the City of Antioch. Young did not present evidence sufficient to obtain summary judgment against the City, and the defendants did not address the municipal-liability claim with facts supporting summary judgment. The court therefore denied both Young’s cross-motion and the defendants’ motion as to that claim.

The court retained supplemental jurisdiction over Young’s negligence claim against Stenger because it arose from the same events as the federal claims. It ruled that summary judgment was not warranted on that claim. The court also denied the defendants’ request to rule that punitive damages were unavailable, finding that a reasonable factfinder could conclude from Young’s version of events that the officers acted with reckless or callous indifference to his federal rights.

Other rulings and case status

The defendants’ request for judicial notice was granted in part and denied in part. Young’s request for judicial notice was denied. The court referred the case to Magistrate Judge Robert M. Illman for settlement proceedings under the Pro Se Prisoner Settlement Program and ordered Young to attend and participate. The court warned that failing to comply could lead to sanctions, including dismissal of part or all of the action; the concluding order specifically states that failure to attend or follow the settlement instructions will result in dismissal with prejudice for failure to prosecute.

The action was stayed until further order, and the clerk was directed to administratively close the file. If the case does not settle, the court stated that it will reopen and proceed to trial. Young’s motion for appointment of counsel was denied without prejudice to renewal if settlement is unsuccessful and the case is scheduled for trial.