## Facts

- Sureshbhai Patel, an elderly Indian man, was walking in his son’s neighborhood in Madison, Alabama, when he was approached and detained by Officer Eric Sloan Parker of the City of Madison Police Department.
- Parker stopped Patel during a period of heightened concern about burglaries in the area and questioned him.
- Patel alleged the stop and detention were not supported by reasonable suspicion or probable cause.
- During the encounter, Parker searched Patel for weapons and found none.
- Parker used a leg-sweep maneuver that took Patel to the ground.
- Patel suffered severe injuries, including permanent partial paralysis.
- Patel sued Parker and the City of Madison under 42 U.S.C. § 1983, asserting Fourth Amendment violations for unlawful seizure/search and excessive force, and also asserted related Alabama state-law claims (including false arrest/false imprisonment and assault and battery based on the use of force).
- The parties filed multiple dispositive motions, including Parker’s motion for summary judgment, the City’s motion for summary judgment (including a request for judgment on the pleadings on certain matters), and Patel’s motion for partial summary judgment.

## Issues

1. Did the evidence, viewed under the summary-judgment standard, permit judgment as a matter of law on Patel’s Fourth Amendment claims challenging the legality of the stop/detention?
2. Could Parker obtain summary judgment (including on qualified-immunity grounds) on Patel’s Fourth Amendment excessive-force claim arising from the leg-sweep takedown?
3. Could the City of Madison obtain summary judgment on § 1983 municipal-liability theories and on the asserted Alabama state-law claims?

## Decision

- The court granted in part and otherwise denied the parties’ summary-judgment motions.
- The court held that genuine disputes of material fact prevented summary judgment on core Fourth Amendment questions tied to the encounter, including the reasonableness of the force used in the takedown.
- The court denied summary judgment to Parker on portions of the case where, taking the facts in Patel’s favor, a jury could find a Fourth Amendment violation and could reject qualified-immunity protection at that stage.
- The court granted summary judgment to the City on certain § 1983 theories to the extent Patel relied on vicarious liability or lacked sufficient proof of an actionable municipal policy/custom or deliberate indifference as required for Monell liability.
- The court granted summary judgment on some state-law theories and denied it on others, depending on whether disputed facts about the encounter and use of force affected applicable Alabama immunity and tort standards.

## Legal Principles

- Summary judgment is proper only when there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law; the record is viewed with reasonable inferences in favor of the nonmovant on each motion.
- A brief investigative detention requires reasonable suspicion supported by specific, articulable facts; an arrest requires probable cause.
- Excessive-force claims arising from a seizure are evaluated under the Fourth Amendment’s objective reasonableness standard, considering factors such as the severity of the suspected offense, immediate threat, and resistance or flight.
- Qualified immunity can bar § 1983 claims against an officer unless the plaintiff shows (on the plaintiff-favorable version of disputed facts at summary judgment) a constitutional violation and that the right was clearly established at the time.
- A municipality is not liable under § 1983 on a respondeat superior theory; municipal liability requires proof that an official policy or custom (or a failure to train/supervise amounting to deliberate indifference) was the moving force behind the constitutional injury.
- Alabama state-law claims against officers and municipalities may be limited by state-law immunity doctrines; where the legality and reasonableness of the officer’s conduct turns on disputed facts, immunity and tort liability often cannot be resolved as a matter of law at summary judgment.

## Conclusion

Patel v. City of Madison, 2018 U.S. Dist. LEXIS 65876 (N.D. Ala. Apr. 19, 2018), resolves cross-motions for summary judgment in a § 1983 case arising from Officer Parker’s stop of Patel and a leg-sweep takedown that caused catastrophic injury: the court allowed key Fourth Amendment claims—especially the excessive-force claim—to proceed because material factual disputes remained, while also disposing of certain claims and theories (including portions of the case against the City) that did not meet the requirements for municipal liability or otherwise could not survive as a matter of law.


Patel v. City of Madison, 2018 U.S. Dist. LEXIS 65876 (2018)