Smith v. Ray

R. R. Ray (defendant), a police officer, knocked on the door of a house looking for a missing juvenile. Amanda Smith (plaintiff) exited the house to the front stoop. Ray asked Smith questions about the missing juvenile. When Ray asked about an acquaintance of the juvenile, Smith told Ray that the acquaintance was inside and turned to retrieve the acquaintance. As Smith turned to the door, Ray slammed the door and grabbed Smith’s shoulder without saying anything. Smith pulled her arm away, asked Ray was he was doing, and uttered a racial epithet at Ray but did not turn or run away from Ray. Ray threw Smith to the ground and jumped on her, pinning Smith to the ground. Ray ordered Smith to show him Smith’s arms, but Smith resisted doing so because Smith was using her free arm to press against the ground, enabling Smith to breathe. Ray punched Smith three times, pulled Smith’s arm behind her back to handcuff her, and yanked Smith up by her ponytail. During the struggle, a pocket knife fell to the ground from Smith’s sweatshirt. However, Ray did not notice the knife until Smith was in handcuffs. Later, Smith sued Ray under a civil-rights claim, alleging that Ray violated her Fourth Amendment right against unreasonable seizures by using excessive force during Smith’s arrest. The district court denied Ray’s motion for summary judgment on the basis of qualified immunity for Smith’s claim. Ray appealed.