Excessive force, conspiracy, and municipal liability under §1983

Weiland v. Palm Beach Cnty. Sheriff's Office, 792 F.3d 1313 (11th Cir. 2015)

District court abused its discretion in dismissing plaintiff’s §1983 claims at the pleading stage on technical, procedural grounds; plaintiff’s allegation as sufficient to state a claim against individual deputies, but not the sheriff’s office as a unit, for use of excessive force and conspiracy to deprive plaintiff of constitutional rights

Background: Christopher Weiland brought an action against the sheriff's office and deputies, asserting claims under § 1983 based on allegations of excessive force and malicious prosecution, and state law claims for excessive force, intentional infliction of emotional distress, and malicious prosecution. On April 6, 2007, Weiland’s father called 911 alleging that his son, who had bipolar disorder, was “acting up,” was “on drugs,” and “probably had a gun.” Two sheriff’s deputies were dispatched and met Weiland’s father outside the house. They then proceeded, with guns drawn, toward Weiland’s bedroom and found him sitting on the edge of his bed with a shotgun in his lap. One of the deputies fired two rounds at Weiland and knocked him off the bed. While he was on the floor bleeding, the other deputy tasered him and then both deputies physically beat him before handcuffing him to a dresser. In an effort to cover up the assault, the deputies fabricated a story that Weiland first ran from the officers then pointed the shotgun at them. The district court dismissed the plaintiff’s § 1983 claims, finding that the complaint failed to comply with the form for pleadings. Weiland appealed.

Holdings: The Court of Appeals held that: (1) the district court had abused its discretion in dismissing the § 1983 claims for failure to comply with requirements for form of pleadings; (2) allegations were sufficient to support claims for use of excessive force and conspiracy to deprive arrestee of his constitutional rights; (3) allegations were insufficient to support claims for § 1983 failure-to-train and conspiracy claims against the sheriff’s office; and (4) allegations were insufficient to support a § 1983 claim that the sheriff’s office had a policy of using internal affairs investigations to cover up use of excessive force against mentally ill citizens.

Notable Points:

Claims against individual deputies: Construing the allegations in the light most favorable to the plaintiff, the Court had little difficulty in deciding that Weiland had stated a claim for use of excessive force. The Court concluded that Weiland’s injuries were cognizable under both the Fourth and Fourteenth Amendments and that his claim specified a “causal connection between the alleged cover up and the specific deprivation of [his] constitutional rights.”

Failure-to-train and claims against the sheriff’s office: Plaintiffs cannot hold local government liable under § 1983 under a respondeat superior theory, so to be successful, a plaintiff must establish that the government unit has a “policy or custom” that caused his injury. The Court held that the claims resulted from an isolated incident involving only two deputies, and that Weiland had not provided any facts supporting either a widespread deficiency in training regarding interactions with mentally ill individuals, or a deliberate indifference to the specialized training needs of deputies interacting with the mentally ill. The Court found the conspiracy allegation against the sheriff’s office similarly deficient.

Found in DMHL Volume 34 Issue 3