Section 1983 Claim Fails due to Qualified Immunity

In Carr v. Deeds, the Fourth Circuit upheld the District Court's grant to summary judgment for the defendants on the plaintiff's claims brought under section 1983. Plaintiff's section 1983 claims alleged that Trooper Deeds unconstitutionally employed excessive force against the decedent, and that Trooper Deeds and Trooper Bradley unconstitutionally employed deadly force during an attempted arrest of the decedent on July 10, 2001.

The court based its decision on qualified immunity, stating that police officers "are shielded from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known." The court said that excessive force is examined under an "objective reasonableness standard," and under the circumstances, a reasonable officer could have believed that the decedent posed a significant threat to serious physical harm to them, their fellow officers, and any others who might encounter him during his flight.

(Contributed by Catherine Runion)