April 20th, 2022

Edwards v. Oliver

Docket: 21-10366
Opinion Date: April 19, 2022
Judge: Carolyn Dineen King
Areas of Law: Government & Administrative Law, Personal Injury

A fifteen-year-old boy was shot and killed by Defendant, a then-officer responding to a 911 call about possible underage drinking. The boy’s family and friends sued Defendant and the City of Balch Springs alleging excessive force. Later, Defendant was separately convicted of murder. The district court denied Defendant’s summary judgment motion claiming qualified immunity.

On appeal, Defendant argued that the facts at the moment of the threat are undisputed and urged the court to exercise jurisdiction over the case on the issue of materiality. The court found that the resolution of this factual dispute is material because it affects both whether Defendant’s use of force was reasonable and whether the force he used violated clearly established law. The court found that if a jury accepts Plaintiffs’ version of the facts as true, particularly as to what occurred in the moments before Defendant shot at the car, the jury could conclude that the officers violated Plaintiffs’ clearly established right to be free from excessive force. Thus, because the factual dispute is material, the court ruled that it lacks jurisdiction to consider the propriety of the summary judgment denial. The court dismissed Defendant’s interlocutory appeal and remanded for further proceedings.

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