Jack Stellington Jack Stellington

Sligh v. City of Conroe, No. 22-40518 (5th Cir. 2023) Excessive Force Claim - K9 Use of Force Case Review

Facts

These are drawn largely from the complaint + bodycam/video attachments (as summarized in the opinion): 

In the early morning hours of July 5, 2018, Olivia Sligh’s partner called 911. He reported that she was suicidal, had hurt herself, and had left her house on foot. He said she was unarmed and not violent.  

The Montgomery County Sheriff’s Office notified the City of Conroe, and a police officer (Sutton) with a trained K-9 (“Thor”) and Deputy Montes responded. Click title to read more…

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Martinez v. Jenneiahn, No. 22-1219 (10th Cir. Jul. 12, 2023 Excessive Force Claim - K9 Use of Force Case Review

Facts

Viewed in the light most favorable to Adrian Martinez (the plaintiff), the key facts are: 

On February 17, 2018, Martinez was in a hospital after being beaten, treated, etc. He left the hospital the next morning wearing only a hospital gown and underwear.  

Felony warrants were outstanding for Martinez. Police were alerted that he had left the hospital without checking out.  

Lafayette, Colorado, police officers searched for him in an apartment complex. At one point, they had information (via canine unit) that Martinez was hiding in a small closet (2.6 ft deep by 4 ft wide) on the 3rd floor. Click title to read more…

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Talmika Bates v. Ryan Rezentes / Brentwood (2024) Excessive Force/Time on Bite Claim K9 Use of Force Case Review

Facts

February 10, 2020: Bates and two others allegedly shoplifted items (approx. $10,000) from an Ulta store. Fled in a vehicle; vehicle collided with a patrol car; got out and hid in the bushes.  

Officer Rezentes commanded his K-9 (named Marco) to search the area; no verbal warning to Bates before deploying the dog.  

The dog located Bates hiding in the bushes and bit her in the head/scalp. Bates allegedly screamed, said she would come out, etc. Click title to read more…

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Ellis v. County of Pierce, No. 24-1361 (2025) Excessive Force Claim - K9 Use of Force Case Review

Facts

Jenni Ellis was the plaintiff. The incident involved Pierce County Deputies and the sheriff’s office’s K9 “Zepp.”  

The deputies responded to a domestic assault call from her boyfriend, Eric Vankirk.  

Upon arrival:

Ellis had left the residence 10 to 15 minutes before the deputies arrived. She was wearing slippers and pajamas and had walked out of the house in the rain.  

Vankirk and his son told the deputies Ellis was unarmed, carrying a bottle of alcohol, and posed no threat. Click title to read more…

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Putman v. Harris (4th Cir. 2023) Excessive Force Claim - K9 Use of Force Case Review

Facts

In May 2019, Dillard Putman sent alarming texts to his wife, threatening self‐harm, saying he had a gun in his mouth, etc. She called 911. Officers arrived and were told about the texts.  

Woods surrounded the property; officers found a rifle but didn’t find Putman immediately; they used a K9 unit, led by Corporal Harris.  

The dog found a scent, and officers located Putman lying in a shallow ditch. No gun was visible. Click title to read more…

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Luethje v. Kyle, 10th Cir., (No. 24-1257, decided Mar. 19, 2025) Excessive Force Claim - K9 Use of Force Case Review

Facts

On February 11, 2022, Deputies Kyle (canine handler) and Kelly (deputy) of the Douglas County Sheriff’s Office responded to a 911 call reporting a broken front window at Tyler Luethje’s residence. A bystander saw someone break the window and then run off, but did not see anyone enter.  

Upon arrival, the deputies observed the broken window, heard a voice from inside the house, but did not hear sounds of violence or cries for help. Click title to read more…

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Barnes v. Felix, 145 S. Ct. 1353 (2025): Use of Force - How Does It Impact K9

Facts

The case involves Ashtian Barnes, who was pulled over by Officer Roberto Felix Jr. in 2016 for unpaid tolls using a rental car. Barnes was unaware of the tolls.  

During the stop, police claimed to smell marijuana and asked Barnes for a license/insurance. Barnes couldn’t produce them immediately and indicated they might be in the trunk.  

Barnes began to drive away. Defendant Felix stepped onto the doorsill of Barnes’s car as it moved, ordered him not to move, and then fired two shots inside the vehicle. Barnes was fatally wounded. Click title to read more…

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K9 and the 3rd Prong: Fleeing or Actively Resisting Arrest

Robinette v Barnes, 854 F.2d 909 (6th Cir. 1988): Using a dog to locate a hidden, unsearched burglary suspect who was actively evading arrest by hiding was reasonable.

Kerr v City of West Palm Beach, 875 F.2d 1546 (11th Cir. 1989): Using a dog against a person who had not committed a crime and posed no threat to the officer was unreasonable. Click title to read more…

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Deliberate Indifference

Canton v. Harris: Understanding Deliberate Indifference in Law Enforcement

When it comes to police liability, the U.S. Supreme Court case City of Canton v. Harris (1989) stands as a critical decision. While many people are familiar with Graham v. Connor or Tennessee v. Garner in the context of use of force, Canton v. Harris set important precedent for how agencies themselves can be held accountable—not just individual officers. Click title to read more…

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Quezada vs. County of Bernalillo

In Quezada v. County of Bernalillo, 944 F.2d 710 (10th Cir. 1991), the U.S. Court of Appeals for the Tenth Circuit examined whether officers’ use of deadly force, under certain circumstances, violated the Fourth Amendment, and also whether the county had liability for failure to train or establish adequate policies. Click title to read more…

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Jack Stellington Jack Stellington

Understanding UOF

Few court decisions have shaped modern law enforcement practices more than Graham v. Connor (1989) and Tennessee v. Garner (1985). Together, these landmark cases form the constitutional foundation for how police use of force is judged in the United States. Click title to read more…

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