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Williams v. City of Jacksonville Police Dept.

Court of Appeals of North Carolina
599 S.E.2d 422 (N.C. App. 2004)


Facts

Williams (plaintiff) was pulled over by police officers Billy Houston and Earl Burkhart (defendants). The defendants made Williams get out of the car at gunpoint and conducted a pat-down search. Williams later sued the defendants and the City of Jacksonville Police Department (department) (defendant) in state court, alleging the defendants had exceeded the scope of the stop and used excessive force. Williams asserted violations of his federal civil rights and the Fourth and Fourteenth Amendments of the United States Constitution. Williams also asserted state law claims, including negligence, false arrest, and assault against the officers, and failure to train against the department. The defendants removed the case to federal court based on the federal claim. The defendants then moved for summary judgment, which was granted on the federal claims. The district judge concluded as a matter of law that: (1) there was probable cause for the stop, (2) the defendants’ conduct was reasonable, and (3) the force used was reasonable. However, the summary judgment order specified that the district court had refused to exercise supplemental jurisdiction over the pendent state law claims and dismissed them without prejudice. Williams sued in state court, asserting only state-law claims. The defendants moved for summary judgment based on res judicata and collateral estoppel, but the motion was denied. The defendants appealed.

Rule of Law

Issue

Holding and Reasoning (Tyson, J.)

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