Hunt v. Massi

A district court issued an arrest warrant for Brian Hunt for failing to pay a fine. Hunt had actually paid the fine, but the payment wasn’t recorded. Four police officers served the warrant at the home of Hunt and his wife (together, Plaintiffs). Hunt requested that he be handcuffed with his hands in front of him because he had recently undergone surgery on his stomach. The officers refused Hunt’s request and, after a scuffle, handcuffed Hunt with his hands behind his back. Plaintiffs sued the officers, asserting violations of Hunt’s federal constitutional rights under 42 U.S.C. 1983 as well as pendent state law claims. The district court declined to grant the police officers qualified immunity on summary judgment. The First Circuit reversed in part, holding (1) Defendants were entitled to qualified immunity on Plaintiffs’ excessive force claim under section 1983, as Hunt had no clearly established right to be cuffed with his hands in front of him when the officers reasonably understood their actions in effectuating the arrest to be constitutional; (2) Defendants were entitled to summary judgment on Plaintiffs’ state law claims of battery and violation of the Massachusetts Civil Rights Act; and (3) the Court lacked jurisdiction to review Plaintiffs’ malicious prosecution claims. View "Hunt v. Massi" on Justia Law