## Facts

- Robert Wilson was arrested for public intoxication and taken to a local jail in Rogers, Arkansas.
- During booking, officers described Wilson as uncooperative and hostile.
- After Wilson’s brother arrived to pick him up, officers decided to keep Wilson in custody.
- Officer David Spain frisked Wilson; Wilson resisted and tried to elbow Spain, and Spain and another officer restrained and handcuffed him.
- Spain led Wilson into a holding cell, shut the door, and inserted the key to lock it while Wilson yelled and pounded on the door.
- Spain withdrew the key, paused, reinserted it to unlock, and pushed the door open; the door struck Wilson and rendered him unconscious.
- Wilson was taken to a hospital, and a police video camera captured most of the events.
- Wilson sued Spain and former police chief Mike Jones under 42 U.S.C. § 1983 and state law, asserting individual-capacity and official-capacity liability for excessive force.

## Issues

1. Whether Spain was entitled to qualified immunity on Wilson’s § 1983 excessive-force claim arising from the cell-door incident.
2. Whether the summary-judgment record (including the videotape) created a genuine dispute that Spain’s conduct was objectively unreasonable under clearly established law.
3. Whether official-capacity and supervisory claims against Jones could proceed absent evidence of a policy/custom or personal involvement and absent a triable underlying constitutional violation.

## Decision

- The Eighth Circuit affirmed summary judgment for Spain and Jones on all claims.
- The court assumed, without deciding, that detainees have a clearly established constitutional right to be free from excessive force while detained.
- On the undisputed record, including the videotape, the court held no reasonable jury could find Spain’s conduct objectively unreasonable under the circumstances.
- Spain was entitled to qualified immunity because a reasonable officer could believe the conduct was lawful in responding to a disruptive, resistant detainee.
- Claims against Jones and the official-capacity claims failed for lack of evidence of a policy or custom, lack of personal involvement/deliberate indifference, and the absence of a triable underlying excessive-force violation.

## Legal Principles

- Qualified immunity bars § 1983 liability unless the plaintiff shows (1) a constitutional violation and (2) that the unlawfulness was clearly established such that a reasonable officer would have known the conduct was unlawful.
- In excessive-force analysis in custodial settings, the focus is objective reasonableness under the circumstances known to the officer, not the injury alone.
- At summary judgment, objective video evidence may foreclose a plaintiff’s account when the recording conclusively establishes the relevant events and eliminates a genuine dispute of material fact.
- Official-capacity (municipal) liability requires proof of a policy or custom causing the alleged constitutional violation; supervisory liability requires personal involvement or deliberate indifference tied to the violation.

## Conclusion

The court affirmed dismissal because the videotaped, undisputed facts showed that Spain’s use of force in opening the holding-cell door was not objectively unreasonable as a matter of clearly established law, entitling him to qualified immunity, and the related official-capacity and supervisory claims lacked the required policy/custom or personal-involvement proof.


Wilson v. Spain, 209 F.3d 713 (8th Cir. 2000)