Brown v. Knowles

CourtDistrict Court, W.D. Virginia
DecidedFebruary 5, 2025
Docket6:24-cv-00029
StatusUnknown

This text of Brown v. Knowles (Brown v. Knowles) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Knowles, (W.D. Va. 2025).

Opinion

AT LYNCHBURG, VA FILED 2/5/2025 IN THE UNITED STATES DISTRICT COURT LAURA A. AUSTIN, CLERK FOR THE WESTERN DISTRICT OF VIRGINIA BY: s/ ARLENE LITTLE LYNCHBURG DIVISION DEPUTY CLERK TONY LEE BROWN, ) Plaintiff, ) Civil Action No. 6:24cv00029 ) ) MEMORANDUM OPINION V. ) ) By: Norman K. Moon BRYCE KNOWLES, ! ) United States District Judge Defendant. ) ) Pro se plaintiff, Tony Lee Brown, filed this 42 U.S.C. § 1983 civil rights action in Lynchburg Circuit Court, and the case was removed to this court on June 12, 2024. Brown alleges that the defendant, Lynchburg Police Department Officer Bryce Knowles, used excessive force against him in violation of the Fourth Amendment. Knowles moves to dismiss. (Dkt. No. 5.) This motion will be granted. I. BACKGROUND The court accepts the allegations in plaintiff's complaint as true for purposes of resolving this motion. Nemet Chevrolet, Inc. v. Consumeraffairs.com, Inc., 591 F.3d 250, 253 (4th Cir. 2009). Plaintiff claims that in the morning hours of November 10, 2023, Officer Knowles was on patrol when he received a radio call from Lynchburg Communications Dispatch to respond to the 5100 block of Boonsboro Road for a stabbing in progress. (Compl. Facts § 1, Dkt. No. 1-1.) At the scene, Officer Knowles encountered a black male, later confirmed to be plaintiff, who appeared to be stabbing a female lying on the ground. (/d. § 2.) From approximately 20 feet away, Officer Knowles yelled for plaintiff to stop multiple times before firing two bullets from

' Plaintiff incorrectly identifies the defendant as Brian Knowles. The Clerk of Court is directed to correct the docket to reflect that the correct name is Bryce Knowles.

his firearm, one entering plaintiff’s back and exiting his chest and one entering the back of plaintiff’s head and exiting his right eye. (Id. ¶¶ 2–4.) The female victim who was stabbed later died at Lynchburg General Hospital. (Id. ¶ 5.) The plaintiff was first transported to Lynchburg General Hospital and then to Roanoke Memorial Hospital where he was treated for life threatening injuries. (Id. ¶ 6.) Plaintiff survived and faces

active criminal charges in relation to this incident. (Id. ¶ 7.) Plaintiff is currently being detained at the Blue Ridge Regional Jail Authority in Lynchburg. Plaintiff alleges that the second shot into the back of his head was unnecessary and excessive because plaintiff no longer posed at threat at that time. Plaintiff also alleges that Officer Knowles violated department policy on deadly force by not announcing himself as a police officer. Plaintiff is now permanently blind in his right eye. (Id. Allegations ¶¶ 1–3.) II. ANALYSIS A. Motion to Dismiss When analyzing a motion to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), the court must view all well-pleaded allegations in the light most favorable to the plaintiff. Ibarra v. United States, 120 F.3d 472, 474 (4th Cir. 1997). “[A] well- pleaded complaint may proceed even if it strikes a savvy judge that actual proof of those facts is

improbable.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556 (2007). Even so, “[f]actual allegations must be enough to raise a right to relief above the speculative level.” Id. at 555. A plaintiff must “plausibly suggest an entitlement to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 681 (2009). “[A] complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Id. at 678 (quoting Twombly, 550 U.S. at 570). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’ Nor does a complaint suffice if it tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555, 557). In addition, pro se plaintiffs are held to a “less stringent standard” than lawyers, and courts construe their pleadings liberally, no matter how “inartfully pleaded.” Erickson v. Pardus, 551 U.S. 89, 94 (2007). Nonetheless, a pro se complaint must still meet the “minimum threshold of plausibility” under Twombly and Iqbal. See Manigault v. Capital One, N.A., CIVIL NO. JKB- 23-223, 2023 WL 3932319, at *2 (D. Md. June 8, 2023). While pro se complaints “represent the work of an untutored hand requiring special judicial solicitude,” district courts are not required to “conjure up questions never squarely presented to them” or to “construct full blown claims from . . . fragments.” Beaudett v. City of Hampton, 775 F.2d 1274, 1277–78 (4th Cir. 1985). B. Fourth Amendment To state a claim under § 1983, a plaintiff must allege that he was deprived of a right secured by the Constitution or laws of the United States, and that the alleged deprivation was committed by a “person” acting under color of state law.

A claim that a police officer employed excessive force during an arrest, investigatory stop, or other seizure is analyzed under the Fourth Amendment’s “objective reasonableness” standard. Graham v. Connor, 490 U.S. 386, 388 (1989); Quinn v. Zerkle, 111 F.4th 281, 296 (4th Cir. 2024). Factors bearing on the reasonableness of a use of force include (1) the severity of the crime at issue, (2) whether the suspect poses an immediate threat to the safety of the officers or others, and (3) whether the suspect is actively resisting arrest or attempting to evade arrest. The reasonableness of a particular use of force is judged from the perspective of a reasonable officer on the scene, rather than with 20/20 vision of hindsight. Id. The standard is objective, and thus without regard to the officer’s subjective intention or motivation. Schultz v. Braga, 455 F.3d 470, 476 (4th Cir. 2006). When deadly force is used, the Fourth Circuit has “a more specific test for objective reasonableness.” Stanton v. Elliot, 25 F.4th 227, 233 (4th Cir. 2022). “In those cases, we consider whether the hypothetical reasonable officer in that situation would have had ‘probable cause to believe that the suspect posed a threat of serious physical harm, either to the officer or to others.’” Waterman v. Batton, 393 F.3d 471, 477 (4th Cir. 2005) (quoting Tennessee v. Garner, 471 U.S. 1, 11 (1985)). That determination must focus on the moment that deadly force was used, not the whole episode. Elliot v. Leavitt, 99 F.3d 640, 643 (4th Cir. 1996). The justification for deadly force can fall away in seconds. Waterman, 393 F.3d at 481. Again, however, in “questioning the split-second decisions of police officers, we must avoid hindsight bias and try to place ourselves in the heat of the moment.” Waterman, 25 F.4th at 233 (citing Elliot, 99 F.3d at 642).

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Related

Tennessee v. Garner
471 U.S. 1 (Supreme Court, 1985)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Nemet Chevrolet, Ltd. v. Consumeraffairs. Com, Inc.
591 F.3d 250 (Fourth Circuit, 2009)
Waterman v. Batton
393 F.3d 471 (Fourth Circuit, 2005)
Hensley Ex Rel. North Carolina v. Price
876 F.3d 573 (Fourth Circuit, 2017)
Jeffery Stanton v. Cory Elliott
25 F.4th 227 (Fourth Circuit, 2022)
Schultz v. Braga
455 F.3d 470 (Fourth Circuit, 2006)

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Brown v. Knowles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-knowles-vawd-2025.