141722P.pdf   07/28/2015  Henry Davis  v.  Michael White
   U.S. Court of Appeals Case No:  14-1722
   U.S. District Court for the Eastern District of Missouri - St. Louis   
   [PUBLISHED] [Loken, Author, with Riley, Chief Judge, and Shepherd, Circuit 
   Judges] 
   Civil case - Civil rights. In action claiming Ferguson, Missouri police 
   officers used excessive force while booking plaintiff, a post-arrest 
   detainee, the district court erred in granting the defendant's motion for 
   summary judgment based on qualified immunity because plaintiff had not 
   alleged a sufficient level of injury;on remand, the district court should 
   apply the proper objective reasonableness standard; no case acknowledging 
   this issue has held that the sort of serious injuries plaintiff alleged - 
   concussion, scalp laceration and bruising - can be considered de minimis 
   as a matter of law for qualified immunity purposes; similarly, the 
   district court erred in granting defendants qualified immunity on 
   plaintiff's state law assault and battery claim; with respect to 
   plaintiff's municipal liability claim, the plaintiff failed to present 
   evidence showing how the Police Department's allegedly poor record keeping 
   directly caused his injury; the officer who executed criminal complaints 
   charging plaintiff with property damage for transferring blood to the 
   officers' uniforms did not violate plaintiff's substantive due process 
   rights as he had a sufficient basis for making the complaints; on remand 
   the district court should consider how to proceed on one police officer's 
   counterclaim for battery against plaintiff.