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Eleventh Circuit Partially Reverses Summary Judgment on Fourth Amendment Bivens Claim

In Robinson v. Sauls, the Eleventh Circuit reversed summary judgment on Monteria Robinson’s Fourth Amendment Bivens claims filed against three officers involved in a gunfight with an armed fugitive. The United States District Court for the Northern District of Georgia granted summary judgment in favor of the officers.

On appeal, the Eleventh Circuit found there was a genuine dispute of fact because video evidence contradicted the testimony of the officers present at the gunfight. The court also stated that shooting an unconscious victim is “an obvious use of excessive force.” Thus, the Eleventh Circuit reversed and remanded the case for two of the Bivens claims.

Paul M. Brock, Robinson v. Sauls, 4 Cumb. L. Rev. Online 25 (2022).


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