Adams v. Metiva
31 F.3d 375 (6th Cir. 1994)
Holding
An officer who used excessive force during an arrest—including beating a suspect who was not resisting—was not entitled to qualified immunity, and the court established that the right to be free from excessive force during an arrest was clearly established in the Sixth Circuit, requiring a fact-intensive inquiry into the totality of the circumstances under Graham v. Connor.
Gene Autrey Adams filed a § 1983 action in the Eastern District of Michigan against Officer Paul Metiva, alleging that the officer used excessive force during his arrest. Adams claimed that despite not resisting, he was subjected to a beating that caused significant injuries. The district court granted summary judgment to Officer Metiva on qualified immunity grounds, but the Sixth Circuit reversed.
The Sixth Circuit held that the right to be free from the use of excessive force during an arrest was clearly established under Graham v. Connor and its progeny. The court applied the Graham factors—severity of the crime at issue, whether the suspect posed an immediate threat to officers or others, and whether the suspect was actively resisting or attempting to flee—and found that a reasonable jury could conclude the force was objectively unreasonable. The court emphasized that when the facts are viewed in the light most favorable to the plaintiff, a non-resisting suspect who poses no threat cannot be subjected to significant physical force.
This decision, cited over 580 times, became a cornerstone of excessive force jurisprudence in the Sixth Circuit covering Michigan, Ohio, Kentucky, and Tennessee. It reinforced that qualified immunity does not protect officers when the constitutional violation is apparent under the Graham framework, even without a factually identical prior case. The court made clear that the reasonableness inquiry is fact-intensive and that summary judgment is often inappropriate in excessive force cases where the parties dispute what happened.
For pro se litigants in Michigan and the Sixth Circuit, Adams v. Metiva provides strong authority for the proposition that officers cannot use significant force against individuals who are compliant and non-threatening. The case is particularly useful when opposing a qualified immunity defense at summary judgment, as it demonstrates that the general Graham standard can be sufficient to clearly establish the law without requiring a case with identical facts.