Ryan v. Lopez
No. 24-40299 (5th Cir. 2025)
Holding
Officers were entitled to qualified immunity where they used force during a traffic stop after the plaintiff physically resisted arrest, even though the initial stop may have been pretextual.
What This Case Is About
This case involves a § 1983 excessive force claim arising from a traffic stop in which officers used force to subdue a driver who physically resisted arrest. The Fifth Circuit addressed whether the officers were entitled to qualified immunity for their use of force during the encounter. The court found that the officers’ actions were not objectively unreasonable under the circumstances.
The Facts
Officers conducted a traffic stop on the plaintiff, Ryan. During the encounter, the situation escalated and officers attempted to place Ryan under arrest. Ryan physically resisted the officers’ efforts to restrain and handcuff him. The officers used force to overcome his resistance and complete the arrest. Ryan subsequently filed a § 1983 lawsuit alleging the officers used excessive force in violation of his Fourth Amendment rights.
The officers moved for summary judgment based on qualified immunity.
What the Court Decided
The Fifth Circuit held that the officers were entitled to qualified immunity. Applying the Graham v. Connor factors, the court examined the severity of the crime at issue, whether the suspect posed an immediate threat to the safety of officers or others, and whether he was actively resisting arrest.
The court found that Ryan’s active physical resistance to arrest was a significant factor justifying the officers’ use of force. When a suspect physically resists arrest, officers are permitted to use a proportionate degree of force to complete the arrest safely. The force used by the officers was found to be commensurate with the level of resistance encountered.
The court also found that even if the constitutional violation were established, the right at issue was not clearly established with sufficient specificity to put the officers on notice that their conduct was unlawful under the particular circumstances they faced.
Why This Case Matters for Your § 1983 Case
Active resistance justifies proportionate force. This case reinforces the well-established principle that officers may use force proportionate to a suspect’s resistance. If you physically resist arrest—even if you believe the arrest is unlawful—courts will weigh that resistance heavily in assessing whether the officers’ force was reasonable.
Pretextual stops do not automatically make force excessive. Even if a traffic stop was arguably pretextual, the excessive force analysis focuses on the moment force was used and the circumstances at that time, not on the officer’s initial motivation for the stop.
Qualified immunity remains a formidable defense. Officers receive the benefit of the doubt when making split-second decisions during rapidly evolving encounters. Absent clearly established law putting officers on notice that specific conduct is unlawful, qualified immunity shields them from liability.
Key Takeaway
When you physically resist arrest, you dramatically weaken any subsequent excessive force claim. Courts assess the reasonableness of force based on the totality of circumstances at the moment force is used, and active resistance is one of the most significant factors weighing in the officers’ favor. Even if the underlying stop or arrest was questionable, physically resisting law enforcement shifts the balance and makes it far more difficult to show that the force used was clearly excessive and objectively unreasonable.