On May 28, 2025, the Eleventh Circuit Court of Appeals decided Daniels v. Blakley[i], which serves as an excellent review of the law related to false arrest and excessive force under the Fourth Amendment. The relevant facts of Daniels, taken directly from the case, are as follows:
On April 25, 2021, Brunswick police officers responded to a reported physical attack at Gracemore Nursing Home. The call described three suspects: two Black females and one Black male with dreadlocks. At the scene, a Gracemore employee informed the officers that the assailants had fled across the street and identified one of the girls as “OhnJyre,” wearing a pink tie-dye shirt.
The officers crossed the street and knocked on the door of a nearby house, where they were met by a woman who identified herself as OhnJyre’s grandmother. While they were speaking, Daniels arrived. He was a Black male with dreadlocks, tied up in a bun, and was wearing a black shirt. He briefly shouted toward the Grac-emore staff.
Officers Blakley and Wood returned to the nursing home, where they viewed a nurse’s cellphone video of the altercation. The footage, while poor in quality, appeared to show a Black male with dreadlocks kicking nursing home staff. Officer Wood asked whether the man who had just yelled at the staff across the street—Daniels—was the person in the video. A Gracemore employee said yes.
The officers returned to the house. Daniels was standing in the driveway. Officer Blakley ordered him to put his hands behind his back, and Daniels appeared to comply. Officer Blakley grabbed his wrists, and as Officer Wood approached to apply handcuffs, Daniels appeared to take a step forward. The officers took him to the ground. Officer Blakley, with a leg across Daniels’s back, held him down while Officer Montgomery handcuffed him. Daniels protested that he had done nothing wrong. Officer Wood replied, “We have you on video,” and told him he was going to jail.
But before they reached the patrol car, a nurse from Grace-more stopped the officers and said Daniels was not the man in the video. She described the actual suspect as shorter and darker-skinned. The officers then uncuffed Daniels and released him. The entire detention lasted just under four minutes.[ii]
Daniels sued and alleged that the officers violated his rights under the Fourth Amendment. The officers were granted summary judgment based on qualified immunity. Daniels appealed to the Eleventh Circuit Court of Appeals.
False Arrest
Daniels first argued that the officers arrested him without probable cause in violation of the Fourth Amendment. The officers argued that they were entitled to qualified immunity.
The court of appeals discussed the requirements of qualified immunity and stated
Qualified immunity protects officers from suit unless they violated a clearly established constitutional right. See Case v. Eslinger, 555 F.3d 1317, 1325 (11th Cir. 2009). To overcome the defense, Daniels must show both [1] a constitutional violation and [2] that the law clearly established the unlawfulness of the officers’ conduct. See Pearson v. Callahan, 555 U.S. 223, 232, 129 S. Ct. 808, 815-16, 172 L. Ed. 2d 565 (2009).[iii]
The court of appeals determined that Daniels’ detention was an “arrest” for the purpose of the Fourth Amendment because the officers handcuffed Daniels, told him he was “going to jail,” and began escorting Daniels to a patrol vehicle. This would lead a reasonable person to believe he was under arrest.
Since Daniels’ encounter with the officers was determined to be an arrest, it must be supported by probable cause to satisfy the Fourth Amendment. However, regarding a claim of false arrest under the Fourth Amendment, officers only need to have “arguable probable cause” to be entitled to qualified immunity. Specifically, the court stated
An arrest is lawful if the officers had probable cause to believe that Daniels committed an offense. See Eslinger, 555 F.3d at 1326-27. Even if actual probable cause was lacking, qualified immunity applies so long as the officers had arguable probable cause—that is, if a reasonable officer in the same situation could have believed that probable cause existed. See id. at 1327.[iv]
The court of appeals then examined the following relevant facts of the case. Officers responded to a fight at a nursing home. One of the suspects was described as a “black male with dreadlocks.” A witness on the scene showed officers a poor-quality cellphone video of a black male with dreadlocks kicking nursing home staff. As officers were investigating, one of the female suspects in the fight arrived on scene. Shortly thereafter, Daniels arrived on scene. He was a black male with dreadlocks. As the police investigated, Daniels yelled at nursing home staff. An officer asked a witness if Daniels was the suspect in the video and the witness said yes. In light of the above facts, the court of appeals stated
Given the totality of the circumstances—the description, the video, the eyewitness identification, and Daniels’s conduct—reasonable officers could have believed he was the suspect.
That is more than enough to satisfy the forgiving standard of arguable probable cause.[v]
Therefore, the court of appeals affirmed the District Court’s grant of summary judgment on the false arrest claim.
Excessive Force
Daniels also argued that the officers used excessive force in violation of the Fourth Amendment when they took him to the ground and handcuffed him.
The court of appeals stated
The Fourth Amendment prohibits officers from using excessive force when seizing a person. The inquiry is objective: whether the force used was reasonable under the circumstances. See Graham v. Connor, 490 U.S. 386, 396, 109 S. Ct. 1865, 1871-72, 104 L. Ed. 2d 443 (1989). Courts evaluate the need for force, the relationship between the need and the amount of force used, and the extent of any injury. See Vinyard v. Wilson, 311 F.3d 1340, 1347 (11th Cir. 2002).[vi]
The court examined the facts relevant to the excessive force claim, which were as follows: (1) the officers had reason to suspect that Daniels was just involved in a violent assault of nursing home staff; (2) an officer told Daniels to put his hands behind his back; (3) Daniels began to comply but when an officer moved close to apply the handcuffs, Daniels “stiffened his shoulders and pulled forward;” (4) there was a struggle and officers took Daniels to the ground; (5) Officer Blakely put pressure on Daniels’ upper legs and Officer Montgomery secured the handcuffs on Daniels; (6) body camera video shows no visible injury to Daniels; (7) Officers used no strikes, chokeholds or weapons on Daniels; and (8) Daniels was on the ground less than one minute and in handcuffs less than four minutes. [Note: Daniels was unhandcuffed and released when another witness told them Daniels was not involved in the previous assault.]
The court held that the force used by the officers, specifically taking Daniels to the ground during a struggle, holding his legs and applying handcuffs was “objectively reasonable” under the Fourth Amendment. The court explained
This level of force was minimal. The officers did not use strikes, chokeholds, or weapons. They did not yell or escalate. They quickly subdued a suspect whom they reasonably believed to be violent. That conduct was neither objectively unreasonable nor constitutionally excessive. See Durruthy v. Pastor, 351 F.3d 1080, 1094 (11th Cir. 2003) ([E]ven if the force applied by [the officer] in effecting the arrest—forcing [the suspect] down to the ground and placing him in handcuffs—was unnecessary, plainly it was not unlawful. The amount of force used was de minim[i]s.”); Nolin v. Isbell, 207 F.3d 1253, 1257-58 (11th Cir. 2000) (“[T]his Circuit has established the principle that the application of de minimis force, without more, will not support a claim for excessive force in violation of the Fourth Amendment.”).[vii]
Therefore, the court of appeals affirmed the District Court’s grant of qualified immunity, finding no constitutional violation.
Note: Court holdings can vary significantly between jurisdictions. As such, it is advisable to seek the advice of a local prosecutor or legal adviser regarding questions on specific cases. This article is not intended to constitute legal advice on a specific case.
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[i] No. 24-12514 (11th Cir. May 28, 2025 Unpublished)
[ii] Id. at 1-3
[iii] Id. at 5 (emphasis added)
[iv] Id. at 6 (emphasis added)
[v] Id. at 7 (emphasis added)
[vi] Id. (emphasis added)
[vii] Id. at 8-9 (emphasis added)
