Goodman v. Harris County

What This Case Is About

Michael Goodman sued Harris County Deputy Constable Terry Ashabranner under § 1983 for excessive force in violation of the Fourth Amendment. The case went to trial, and the jury found that Ashabranner’s use of force was “clearly excessive to the need and objectively unreasonable.” On appeal, Ashabranner challenged the jury instructions, arguing they failed to properly present the qualified immunity defense. The Fifth Circuit affirmed.

The Facts

On April 14, 2002, Deputy Constable Terry Ashabranner used force against Michael Goodman during an encounter. The specific details of the force are addressed in the trial record, but the case centers on the legal standards applied to the jury’s evaluation of the officer’s conduct.

At trial, the jury was asked: “Do you find by a preponderance of the evidence that Defendant Deputy Constable Terry Ashabranner’s use of force was clearly excessive to the need and was objectively unreasonable?” The jury answered “Yes.”

Ashabranner appealed, arguing that the jury instruction failed to properly submit the second step of the qualified immunity analysis — whether his conduct was “objectively reasonable under clearly established law existing at the time of the incident.” He sought an instruction that specifically asked whether “no reasonable officer” possessing knowledge of clearly established law could have believed the force was lawful.

What the Court Decided

The Fifth Circuit affirmed the jury’s verdict. The court held that the jury instruction was adequate when read as a whole and in conjunction with the general charge. The instruction asked whether the force was “objectively unreasonable” — the very standard required by the second step of the qualified immunity analysis. The trial court had also separately instructed the jury on qualified immunity.

The court applied a deferential standard of review for jury instructions: whether the charge “as a whole is a correct statement of the law” and whether it “clearly instructs the jury on the law applicable to the facts.” The court examined three factors: (1) whether the interrogatories adequately presented the contested issues; (2) whether the submission was “fair”; and (3) whether the “ultimate questions of fact” were clearly submitted. All factors were satisfied.

The court concluded that the district court did not abuse its discretion in framing the jury instructions and affirmed the judgment.

Why This Case Matters for Your § 1983 Case

Goodman is important for litigants who get past summary judgment and actually reach trial on an excessive force claim. The case establishes that a jury instruction asking whether force was “clearly excessive and objectively unreasonable” properly captures the qualified immunity standard. You don’t need an instruction that uses the exact formulation from every qualified immunity case — the instruction just needs to correctly state the law and fairly submit the ultimate factual questions to the jury.

If you’re preparing jury instructions for an excessive force trial, Goodman is your authority for a straightforward instruction that tracks the Graham v. Connor objective reasonableness standard. The defendant officer cannot demand an instruction that makes it harder for the jury to find liability, as long as the existing instruction correctly states the law.

Key Takeaway

When an excessive force case reaches a jury, the instruction must properly present the qualified immunity question: was the officer’s force “objectively unreasonable”? A jury that finds force “clearly excessive and objectively unreasonable” has effectively resolved the qualified immunity issue. The Fifth Circuit gives trial courts discretion in crafting jury instructions and will uphold them as long as the charge, read as a whole, correctly states the law and fairly submits the factual issues.