In Wilson v. Flynn, the Fourth Circuit affirmed the district court's grant summary in favor of two police officers based on qualified immunity. At base, Officers Flynn and Butler arrived at the Wilson house and confronted a volatile domestic disturbance. Wilson was drunk, assaulted his wife, had a gun in the house, and actively resisted arrest. These factors supported the conclusion that the injuries Wilson suffered in the melee did not constitute a deprivation of a constitutional right. (As a result of the incident, the left side of Wilson's face was badly bruised and swollen, and he suffered a nasal fracture.)
The officers' use of force, according to the panel, was not objectively unreasonable under these circumstances.
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