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Eighth Circuit Affirms Dismissal of Excessive Force Case

by Christopher Zoukis

The United States Court of Appeals for the Eighth Circuit affirmed the dismissal of a civil rights claim brought against the Jefferson County, Missouri Sheriff's Department by a man beaten during a traffic stop.

Edward C. Schoettle, an insulin-dependent diabetic, was driving his truck down a highway on November 6, 2010. When he became lightheaded, he pulled over to eat candy and glucose tablets. While pulled over, he passed out.

Deputy Matthew Hudson observed Schoettle slumped over in the truck and investigated. When he knocked on Schoettle's window, Schoettle told him that he had been eating candy to recover from low blood sugar. Hudson decided that Schoettle was drunk, and called for backup.

Deputy Aaron Piefer, the DWI enforcement officer, arrived on the scene. The officers demanded that Schoettle exit the vehicle, but he refused – noting that he had done nothing wrong. No prizes for guessing what happened next.

Schoettle "resisted" being yanked from his own vehicle for no lawful reason, and was subsequently pepper sprayed and struck about the head and body by the officers. When he told the officers that he had a gun in his waistband, Deputy Piefer removed it and threw the loaded gun on the ground. Schoettle asked the officers if they were stupid.

After Schoettle was subdued and treated for hypoglycemia, he became calm. It was later determined that he had sustained a broken rib during the police beating.

Schoettle sued Jefferson County, Sheriff Oliver Glenn Boyer, and Deputies Matthew Hudson and Aaron Piefer. He alleged excessive use of force, refusal of medical assistance, supervisory liability, municipal liability, and assault and battery. The defendants all moved for summary judgment, which the district court granted.

On appeal, the Eighth Circuit rejected Schoettle's argument that there were genuine issues of material fact which precluded summary judgment. The court found that because the officers had reasonable suspicion, they were within their rights to stop and question Schoettle. Further, the court found that because an objective officer could have concluded that Schoettle was drunk, they were justified in using force to remove him.

The court also found that the beating of Schoettle was not excessive, regardless of when the officers became aware of his medical condition. This conclusion is interesting, for it begs the question: would an objective officer really drag an otherwise law-abiding citizen who he knew was experiencing a diabetic emergency out of a car, pepper spray him, and beat him until his rib is broken? And better yet – should he?

The Eighth Circuit says yes. Regardless of when they became aware that Schoettle was suffering a hypoglycemic episode, "[the officers] were still confronted with a belligerent and impaired man who was refusing to comply with their orders to exit the vehicle and who was physically resisting their attempts to remove him from it."

The court seems to have forgotten that Schoettle did nothing wrong. Since when do we approve of storm troopers yanking citizens suffering from medical emergencies from their vehicles and beating them into submission even when they know the citizen is experiencing a medical emergency?

See: Schoettle v. Jefferson County,788 F.3d 855 (8th Cir. 2015). 

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Related legal case

Schoettle v. Jefferson County

 

 

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