DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
202161P.pdf 03/18/2021 L.G. v. Keisha Edwards
U.S. Court of Appeals Case No: 20-2161
U.S. District Court for the Western District of Missouri - Jefferson City
[PUBLISHED] [Arnold, Author, with Smith, Chief Judge, and Stras, Circuit
Judge]
Civil case - Civil rights. Plaintiff, a minor high school student, who
defendant, the school resource officer, escorted to an office for
questioning by police officers, alleged defendant violated her civil
rights by seizing her without probable cause; the district court denied
defendant's motion for summary judgment based on qualified immunity and
defendant appeals. Held: plaintiff failed to establish that defendant's
conduct violated a clearly established constitutional or statutory right;
two facts distinguish this case from those where the court has found a
violation; first, the defendant's involvement in the alleged seizure was
minimal and ministerial and, second, the incident occurred in a public
school setting where it would not necessarily be clear at what point a
student has been unreasonably seized for constitutional purposes; given
these factors, existing circuit precedents would not have alerted a
reasonable officer in defendant's position that she was violating
plaintiff's constitutional rights by escorting her to a room containing
two police officers and closing the door; nor was there a robust consensus
of persuasive authority that created a clearly established right; nor is
the kind of case where a general constitutional right applies with obvious
clarity; reversed and remanded with directions to dismiss plaintiff's
Section 1983 claims against defendant.