Harris v. Janes

CourtCourt of Appeals for the Tenth Circuit
DecidedJune 29, 2020
Docket19-3191
StatusUnpublished

This text of Harris v. Janes (Harris v. Janes) 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
Harris v. Janes, (10th Cir. 2020).

Opinion

FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT June 29, 2020 _________________________________ Christopher M. Wolpert Clerk of Court TIMOTHY C. HARRIS,

Plaintiff - Appellee,

v. No. 19-3191 (D.C. No. 5:18-CV-04124-SAC-TJJ) CHRISTOPHER JANES, (D. Kan.)

Defendant - Appellant,

and

CITY OF TOPEKA, KANSAS,

Defendant. _________________________________

ORDER AND JUDGMENT * _________________________________

Before BRISCOE, LUCERO, and HARTZ, Circuit Judges. _________________________________

Christopher Janes, a City of Topeka police officer, appeals from a district

court order denying him qualified immunity in Timothy Harris’ excessive-force

lawsuit. We dismiss the appeal for lack of jurisdiction.

* After examining the briefs and appellate record, this panel has determined unanimously to honor the parties’ request for a decision on the briefs without oral argument. See Fed. R. App. P. 34(f); 10th Cir. R. 34.1(G). The case is therefore submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. I

This appeal stems from Officer Janes’ stop and arrest of Harris in January

2018. 1 Janes spotted Harris’ car parked the wrong direction on a street and

proceeded to detain Harris for (1) an outstanding probation-violation warrant and

(2) reports of his wrongful possession of his girlfriend’s belongings. As Janes tried

to handcuff him, Harris repeatedly turned around and tried to address Janes. But

after being handcuffed, Harris stopped resisting and cooperated with Janes to walk to

his patrol car. 2

At this point, the encounter turned violent. According to Harris, Janes threw

him down onto the curb and street. Because Harris was handcuffed, he could not

break his fall and landed face-first on the curb, leaving “blood in the street.” Janes

put his knee on Harris’ back. A passenger in Harris’ car, Airel Gatewood, exited the

vehicle and approached Janes, screaming at Janes to get off of Harris. Janes sprayed

Harris with pepper spray and punched him several times. Janes repeatedly ordered

Harris not to get up, but Harris protested that he was not trying to get up, that Janes

1 When reviewing a district court’s denial of qualified immunity at the summary judgment stage, we generally do not make our own factual determinations but rely instead on the district court’s recitation of the facts. See Johnson v. Jones, 515 U.S. 304, 319 (1995). “[C]ourts are required to view the facts and draw reasonable inferences in the light most favorable to the party opposing the summary judgment motion.” Scott v. Harris, 550 U.S. 372, 378 (2007) (quotation and alteration omitted). We therefore draw our review of the facts from the district court’s thorough and detailed account, from which it appropriately drew reasonable inferences in the light most favorable to Harris. See Harris v. City of Topeka, No. 18-4124-SAC, 2019 WL 3573582, at *2-4 (D. Kan. Aug. 6, 2019). 2 At this point, Janes’ body camera video turns to the street and provides no useful video, only audio, of the incident. 2 was on top of him, and that he could not breathe. Janes replied that Harris could

breathe and that “it’s the pepper spray.” Harris denies that he was attempting to

evade arrest or reach for Janes’ utility belt or weapons.

Other officers arrived, secured the scene, and arrested Harris and Gatewood.

Harris was charged with disobeying lawful orders, obstruction, battery on a police

officer, and illegal parking. He filed a 42 U.S.C. § 1983 lawsuit against Janes and

the City of Topeka, alleging that Janes used excessive force. In response, Janes filed

a motion for summary judgment, asserting qualified immunity.

Analyzing the excessive-force factors identified in Graham v. Connor,

490 U.S. 386 (1989), 3 the district court determined that Harris had raised a genuine

issue of material fact as to whether Janes violated his Fourth Amendment rights. In

particular, the court concluded that once Harris was handcuffed and announced he

would cooperate in walking with Janes to the patrol car, a reasonable jury could find

that Janes should have recognized that Harris did not present an immediate threat to

officer safety. 4 The court further concluded that the dangers present before Harris

was handcuffed did not justify the use of force after circumstances had changed.

Consequently, the court determined that “a reasonable jury could find that [Janes’ use

of] force violated [Harris’] Fourth Amendment rights.”

3 The Graham factors include “the severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the officers or others, and whether he is actively resisting arrest or attempting to evade arrest by flight.” Id. at 396. 4 The court also determined that the first Graham factor—severity of the crime at issue—supported this conclusion because Harris’ probation violation was not severe enough to justify the level of force Janes used. 3 Regarding the second prong of the qualified-immunity analysis, the district

court concluded that Janes’ use of force violated clearly established law. The court

determined that Tenth Circuit precedent made it clear to any reasonable officer in

Janes’ position “that an arrestee on a probation violation warrant would have a right

not to be tackled to [the] ground, kneed in the back, punched in the face, and pepper-

sprayed after he was handcuffed, was cooperating with the officer’s request to go to

the patrol car, was not physically resisting or attempting to evade the officer, and was

not attempting to reach for the officer’s belt or weapons.” Janes timely appealed.

II

“We review the district court’s denial of summary judgment on qualified

immunity grounds de novo, with our review limited to purely legal issues.” Quinn v.

Young, 780 F.3d 998, 1004 (10th Cir. 2015) (quotation omitted). When a defendant

claims qualified immunity, “the onus is on the plaintiff to demonstrate (1) that the

official violated a statutory or constitutional right, and (2) that the right was clearly

established at the time of the challenged conduct.” Id. (quotation and alteration

omitted). Because our interlocutory jurisdiction to review a denial of qualified

immunity is limited to considering “whether the set of facts identified by the district

court is sufficient to establish a violation of a clearly established constitutional

right,” Attocknie v. Smith, 798 F.3d 1252, 1256 (10th Cir. 2015) (quotation omitted),

the defendant must “be willing to concede the most favorable view of the facts to the

plaintiff for purposes of the appeal” and discuss only legal issues, Henderson v.

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Related

Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Johnson v. Jones
515 U.S. 304 (Supreme Court, 1995)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Romero v. Storey
672 F.3d 880 (Tenth Circuit, 2012)
Roosevelt-Hennix v. Prickett
717 F.3d 751 (Tenth Circuit, 2013)
Pahls v. Thomas
718 F.3d 1210 (Tenth Circuit, 2013)
Quinn v. Young
780 F.3d 998 (Tenth Circuit, 2015)
Attocknie Ex Rel. M.P. v. Smith
798 F.3d 1252 (Tenth Circuit, 2015)
Cox v. Glanz
800 F.3d 1231 (Tenth Circuit, 2015)
Henderson v. Glanz
813 F.3d 938 (Tenth Circuit, 2015)
Perea v. Baca
817 F.3d 1198 (Tenth Circuit, 2016)
A.M. Ex Rel. F.M. v. Holmes
830 F.3d 1123 (Tenth Circuit, 2016)
Lee v. Tucker
904 F.3d 1145 (Tenth Circuit, 2018)
McCowan v. Morales
945 F.3d 1276 (Tenth Circuit, 2019)

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