Pateman v. The City of White Plains

Background

Charles Pateman sued the City of White Plains, Sergeant LaValle Larrier, Police Officer Paul Wenzel, Lieutenant Edward Robinson, and unidentified police officers under 42 U.S.C. § 1983 and New York law. He alleged that officers used excessive force during his arrest on January 25, 2017, tightly handcuffed him, failed to intervene, failed to provide adequate medical care, and caused related injuries. His claims included federal excessive-force, medical-care, failure-to-intervene, and supervisory-liability claims, along with state-law assault and battery, negligence, intentional infliction of emotional distress, and claims based on the City’s responsibility for its officers.

The incident began when police responded to a domestic-dispute call at 33 Barker Avenue in White Plains. Pateman arrived and tried to go upstairs, despite officers’ instructions to remain in the lobby. The court found that video evidence showed Pateman initially resisted being handcuffed and that the force used during the initial arrest was not unreasonable. But the court found factual disputes about whether Larrier and Wenzel pushed Pateman, caused him to fall and hit his head, pulled him from the floor, and applied handcuffs so tightly that his wrists bled. The record also contained conflicting evidence about the seriousness and cause of his injuries and about the timing and adequacy of medical care.

Rulings

Judge Kenneth M. Karas granted in part and denied in part the defendants’ motion for summary judgment. Summary judgment is a decision without a trial when no genuine dispute of important fact requires a jury’s consideration.

The court granted summary judgment on:

- Pateman’s federal excessive-force claims against Larrier and Wenzel concerning the initial arrest. - Pateman’s federal excessive-force and failure-to-intervene claims against Robinson. - Pateman’s federal claims that Larrier, Wenzel, and Robinson were deliberately indifferent to his medical needs. - Pateman’s supervisory-liability claims against Larrier and Robinson. - Pateman’s state negligence claims based on excessive force, except for the handcuffing allegations. - Pateman’s intentional-infliction-of-emotional-distress claims against all defendants.

The court denied summary judgment on:

- Pateman’s federal excessive-force claims against Larrier and Wenzel concerning the alleged push and fall and the tight handcuffing. - Pateman’s New York assault-and-battery claims against White Plains, Larrier, and Wenzel. - Pateman’s negligence claims against White Plains, Larrier, and Wenzel concerning the handcuffing. - Pateman’s negligence claims against White Plains, Larrier, Wenzel, and Robinson concerning the alleged delay in or denial of medical treatment.

The court also concluded that qualified immunity could not be resolved for Larrier and Wenzel at this stage because disputed facts remained about the alleged push and tight handcuffing. The order directed the Clerk of Court to terminate the pending motion.