Glenn v. City of Tyler

What This Case Is About

Deborah Ann Glenn was arrested by Tyler, Texas police officers for family violence assault against her daughter. She sued under § 1983, claiming the officers arrested her without probable cause, subjected her to an unlawful search, and used excessive force by intentionally handcuffing her too tightly. The Fifth Circuit found that genuine issues of material fact precluded qualified immunity on several of Glenn’s claims.

The Facts

Glenn’s lawsuit arose from her arrest for allegedly assaulting her daughter. Officers Kyle Rhodes and Brian Tomlin of the Tyler Police Department responded to a domestic disturbance call. Glenn alleged that: (1) the officers arrested her without probable cause; (2) she was subjected to an unlawful search and seizure; (3) Officer Rhodes intentionally handcuffed her hands too tightly, causing injury; and (4) the officers violated the Americans with Disabilities Act.

The defendants moved for summary judgment, arguing that the officers were entitled to qualified immunity and that the city was therefore entitled to judgment as well. Glenn countered that genuine issues of material fact precluded summary judgment.

The district court granted summary judgment on the ADA claim but denied it on the constitutional claims. The officers and city filed an interlocutory appeal.

What the Court Decided

The Fifth Circuit reversed the district court’s denial of qualified immunity and remanded for further proceedings. The court analyzed each of Glenn’s claims under the two-prong qualified immunity framework: (1) whether the facts alleged show a constitutional violation, and (2) whether the right was clearly established.

On the false arrest claim, the court examined whether the officers had probable cause to believe Glenn had committed family violence assault. The factual dispute about what the officers knew and observed at the scene created genuine issues of material fact that could not be resolved on summary judgment.

On the excessive force claim involving tight handcuffing, the court applied the Graham v. Connor objective reasonableness test. Intentionally applying handcuffs too tightly can constitute excessive force, but the court had to determine whether the right to be free from overly tight handcuffs was clearly established at the time.

The court noted it lacked jurisdiction over the claims against the city, since municipalities cannot claim qualified immunity.

Why This Case Matters for Your § 1983 Case

Glenn is relevant to two common § 1983 claim types. First, for false arrest claims, it reinforces that disputed facts about what officers knew at the time of arrest — including conflicting witness accounts at a domestic disturbance scene — can preclude summary judgment. The question of probable cause is often fact-intensive and may be for a jury to decide.

Second, for excessive force claims based on handcuffing, Glenn establishes that intentionally applying handcuffs too tightly can violate the Fourth Amendment. This is a frequently litigated issue: plaintiffs must show that the handcuffing caused more than de minimis injury and that the tightness was unreasonable under the circumstances.

Key Takeaway

Officers who arrest someone without probable cause or who intentionally handcuff too tightly may face § 1983 liability. When the facts about what officers knew at the time of arrest are disputed, qualified immunity cannot be resolved at summary judgment — the case must go to a jury. And while handcuffing is a routine part of arrest, deliberately causing unnecessary pain through overly tight handcuffs can constitute excessive force under Graham v. Connor.