Roberts v. City of Forest Acres
902 F. Supp. 662 (D.S.C. 1995)
Holding
The court denied summary judgment for the city and officer on excessive force and municipal liability claims where evidence showed an officer used force significantly disproportionate to the threat posed during a traffic stop, and the city had inadequate training and supervision of its officers regarding use of force.
What This Case Is About
John E. Roberts was stopped by Officer Daniel Jacko of the City of Forest Acres Police Department in Columbia, South Carolina. During the encounter, Officer Jacko used force that Roberts alleged was grossly disproportionate to any threat Roberts posed. Roberts filed suit under 42 U.S.C. § 1983 against both Officer Jacko individually and the City of Forest Acres, claiming excessive force in violation of the Fourth Amendment and arguing that the city was liable under Monell v. Department of Social Services for inadequate training and supervision.
What the Court Decided
The federal district court in South Carolina denied summary judgment on both the individual excessive force claim against Officer Jacko and the municipal liability claim against the City of Forest Acres. The court applied the Graham v. Connor objective reasonableness standard, examining the severity of the crime at issue, whether the suspect posed an immediate threat, and whether the suspect was actively resisting or attempting to evade arrest. The court found genuine issues of material fact existed regarding whether the force used was objectively reasonable under the circumstances. On the municipal liability claim, the court found sufficient evidence that the city’s training and supervision practices could constitute deliberate indifference to the constitutional rights of citizens.
Why This Case Matters for Pro Se Litigants
This South Carolina case demonstrates how excessive force claims survive summary judgment when there is a genuine factual dispute about whether the level of force was reasonable. It is a useful reference for anyone building a § 1983 case in South Carolina, as it applies the Graham v. Connor factors in a straightforward traffic-stop context. It also shows how Monell municipal liability works—a plaintiff can sue the city itself if they can show the city’s policies, customs, or deliberate indifference to training caused the constitutional violation. For pro se litigants, this case illustrates that even at the summary judgment stage, if the facts are genuinely in dispute, the case should go to a jury.