The case stems from the 2016 shooting death of Terence Crutcher, an unarmed Black man who was killed by Officer Betty Shelby near his stalled SUV in Tulsa. Michael Manning, administrator of Crutcher's estate, sued Shelby under Section 1983 for excessive force and brought Monell claims against the City of Tulsa for inadequate training, hiring practices, and disciplinary failures that allegedly fostered a culture of excessive force.
Circuit Judge Stephanie A. Moritz wrote that the district court erred by failing to view disputed facts in the plaintiff's favor and by defining clearly established law too narrowly. 'Because the district court failed to view the facts in a light most favorable to the Estate and erred in analyzing clearly established law by defining the right at issue too narrowly, we reverse its grant of summary judgment to Shelby,' Moritz wrote. The court found that under the proper standard, Crutcher 'was standing with his hands up, unarmed, next to the mostly rolled-up driver's side window, no weapon within reach' when shot.
The district court had originally granted Shelby qualified immunity and dismissed the Monell claims against Tulsa for failure to state a claim. The court also declined to exercise supplemental jurisdiction over state wrongful death claims after dismissing the federal claims. Manning appealed both rulings to the Tenth Circuit.
While the appeals court revived the excessive force claim against Shelby, it affirmed dismissal of the Monell claims, finding Manning failed to adequately allege municipal liability. The court remanded for the district court to reconsider exercising supplemental jurisdiction over the state law claims. The ruling represents a significant victory for civil rights plaintiffs in cases involving police shootings of unarmed individuals.