Estate of Jason Waterhouse v. Direzza

129 F.4th 1212
CourtCourt of Appeals for the Tenth Circuit
DecidedFebruary 20, 2025
Docket23-1360
StatusPublished
Cited by6 cases

This text of 129 F.4th 1212 (Estate of Jason Waterhouse v. Direzza) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Jason Waterhouse v. Direzza, 129 F.4th 1212 (10th Cir. 2025).

Opinion

Appellate Case: 23-1360 Document: 64-1 Date Filed: 02/20/2025 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS February 20, 2025

Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

ESTATE OF JASON WATERHOUSE, through its personal representative Heather Lopez; AMBER WATERHOUSE, daughter of Jason Waterhouse deceased,

Plaintiffs - Appellants,

v. No. 23-1360

MARC DIREZZA, Sergeant, in his individual capacity; CITY OF LAKEWOOD, COLORADO, a municipality,

Defendants - Appellees. _________________________________

Appeal from the United States District Court for the District of Colorado (D.C. No. 1:21-CV-00982-KAS) _________________________________

Norman R. Mueller, Haddon, Morgan & Foreman, P.C., Denver, Colorado, (Adam Mueller, Haddon, Morgan & Foreman, P.C., and Tim Galluzzi, Cheney Galluzzi & Howard, LLC, Denver, Colorado, with him on the briefs), for Plaintiffs-Appellants.

Patrick T. Freeman, Lakewood City Attorney’s Office, Lakewood, Colorado, (John VanLandschoot, Lakewood City Attorney’s Office, Lakewood, Colorado, with him on the briefs), for Defendants-Appellees. _________________________________

Before HARTZ, PHILLIPS, and FEDERICO, Circuit Judges. _________________________________

HARTZ, Circuit Judge. Appellate Case: 23-1360 Document: 64-1 Date Filed: 02/20/2025 Page: 2

_________________________________

Jason Waterhouse was high on methamphetamine and acting destructively in his

sister’s home. By the time Lakewood Police Department (LPD) officers arrived, he had

barricaded himself in the basement. Officers tried for over an hour to get him to come

out; but rather than cooperating, he started a fire. Seven officers went down to the

basement to try to find the source of the fire and extricate Mr. Waterhouse. They saw him

shoving a large stick through the wall before slamming the bedroom door shut. It quickly

became apparent that the fire and the smoke were more serious than the officers had

anticipated, and they were ordered to evacuate.

Assigned to provide lethal cover, Sergeant Marc Direzza was one of the last two

officers in the basement. As several others were still hurrying up the stairs, Mr.

Waterhouse burst out of the bedroom, heading toward the two remaining officers, who

were six-to-ten feet from the door. The other officer fired his beanbag shotgun, hitting

Mr. Waterhouse. Sergeant Direzza fired his pistol three times in rapid succession. One of

the bullets struck Mr. Waterhouse in the back, killing him.

Mr. Waterhouse’s estate (the Estate) brought a Fourth Amendment excessive-force

claim under 42 U.S.C. § 1983 in the United States District Court for the District of

Colorado. The district court granted Sergeant Direzza summary judgment on the § 1983

claim. Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

The issue in this appeal is whether Sergeant Direzza is entitled to qualified

immunity. We conclude that he is. Under these dangerous circumstances, his use of lethal

force complied with the Fourth Amendment. Even if Mr. Waterhouse was not carrying a

Page 2 Appellate Case: 23-1360 Document: 64-1 Date Filed: 02/20/2025 Page: 3

weapon when he was shot, Sergeant Direzza could reasonably believe that he posed a

threat of serious physical harm to himself or other officers. Given the fire and smoke, a

wrestling match in the basement could have been fatal. In addition, Sergeant Direzza did

not violate clearly established law. No controlling precedent forbids officers from using

lethal force in such circumstances.

I. BACKGROUND

A. The Shooting

Unless otherwise indicated, the following facts were undisputed in the

summary-judgment proceedings.

On December 19, 2019, a woman called 911. Having spoken to Heather Lopez,

Mr. Waterhouse’s sister, she relayed the following information: Mr. Waterhouse

“was agitated and had barricaded himself under the stairs” at Ms. Lopez’s home; “he

had been like this” since the previous night; he was “on something,” most likely

alcohol and methamphetamine (“his drug of choice”); “he had done things like this

before” while drinking; he had never been diagnosed with a mental illness, but he

was “hearing voices and thought that someone was coming to hurt him”; he had

constructed a “shiv” by attaching a blade to a screwdriver, though Ms. Lopez had

taken it away from him; he was now “armed with a hammer” and “striking objects”

with it; and there were “no guns in the house,” but Ms. Lopez did not know if he had

any other weapons. Joint App. at 1052–53, 1064 (internal quotation marks omitted).

When LPD officers reached Ms. Lopez’s home at 3:32 p.m., she told them that

Mr. Waterhouse was “out on bond for assaulting an officer.” Id. at 1053. From

Page 3 Appellate Case: 23-1360 Document: 64-1 Date Filed: 02/20/2025 Page: 4

outside, officers ordered Mr. Waterhouse to come out of the basement. But they

heard only “crashing sounds.” Id. Given Mr. Waterhouse’s history of usage and

bizarre behavior, the officers believed that Mr. Waterhouse was high on

methamphetamine. (Testing later confirmed so.) They told Ms. Lopez that they

would “probably not try to force [him] out” if she did not want him to be charged for

the damage. She responded, “Then yeah, . . . if that’s what it takes cuz I can’t deal

with this.” Id. at 1054.

Sergeant Eric Ebeling, a SWAT negotiator, entered the home with several

others, moving to the top of the basement stairs. He tried to coax Mr. Waterhouse

out, but Mr. Waterhouse, who was wielding a hammer, refused. The parties debate

whether he was using the hammer to “violent[ly] attack[]” the house, Aplee. Br. at 5,

or just to “barricade himself” under the stairs, Aplt. Br. at 7. Regardless, he was

belligerent, shouting back: “get some,” “come get some,” “I want to get hurt,”

“faggots,” “n***,” “mother fucker,” “I got something for you,” and “shit’s gonna fly

mother fucker.” Joint App. at 1054–55 (internal quotation marks omitted). For more

than an hour, the officers tried “various de-escalation techniques” to resolve the

situation peacefully. Id. at 1055. Instead of complying, Mr. Waterhouse started a fire.

During this standoff, Sergeant Direzza, a tactical supervisor with LPD SWAT

who had extensive de-escalation experience, contacted Sergeant Ebeling to offer his

assistance. Sergeant Ebeling gratefully accepted. Shortly after Sergeant Direzza

arrived, smoke began drifting out of the basement. But Mr. Waterhouse remained

downstairs, causing Sergeant Ebeling to worry that the fire department would be

Page 4 Appellate Case: 23-1360 Document: 64-1 Date Filed: 02/20/2025 Page: 5

unable to deal with the fire. He decided that they would try to extract Mr.

Waterhouse and locate the fire.

At 5:23 p.m. seven officers descended into the basement. While others had

non-lethal or less-lethal weapons—including tasers and a beanbag shotgun—Sergeant

Direzza was carrying a pistol and was assigned to provide lethal cover for the other

officers. The Estate asserts that the sergeant’s “presence was not required,” Aplt. Br.

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Bluebook (online)
129 F.4th 1212, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-jason-waterhouse-v-direzza-ca10-2025.