“Only De Minimis Force”: The Eleventh Circuit Re-affirms a Narrow Excessive-Force Threshold for School Resource Officers in Glenn v. Britt (2025)

1. Introduction

Glenn v. Britt, No. 23-11890 (11th Cir. July 3 2025), arises from a school-house encounter: a 14-year-old ninth-grader seized and briefly man-handled by two school resource officers (“SROs”) after a fracas around a vending machine. The student’s mother sued under 42 U.S.C. §1983 for Fourth-Amendment excessive force, unlawful seizure, excessive corporal punishment, and state-law battery. The district court granted summary judgment to the officers, holding that the officers used only de minimis force and, in any event, enjoyed qualified immunity. On appeal, a unanimous Eleventh Circuit panel (Branch, Luck & Lagoa, JJ.) affirmed.

The decision is significant for two reasons. First, it tightens the Circuit’s definition of “de minimis force” in the unique context of SRO–student encounters, adding to a growing line of cases in which minor physical conduct—even toward minors—is deemed constitutionally insignificant. Second, it underscores how high the qualified-immunity hurdle remains where the plaintiff cannot first show a constitutional violation. In effect, Glenn cements a precedent that fleeting physical restraints causing only minor bruises seldom cross the Fourth-Amendment line, even when the restrained person is a child.

2. Summary of the Judgment

The panel reviewed de novo the district court’s summary-judgment ruling.
Because the plaintiff conceded the officers were acting within discretionary authority, the panel focused on the first prong of qualified immunity: whether a constitutional violation occurred.
Applying Eleventh-Circuit “de minimis force” doctrine, the court held:
- Officer Britt’s brief hand-to-neck restraint—lasting at most two seconds—constituted only de minimis force.
- Officer Bartlett’s waist-lift takedown, in which the student struck a wall and received minor bruises, likewise was de minimis.
Because no constitutional violation occurred, the court did not reach whether the right was “clearly established.”
All claims therefore failed, and the district court’s judgment in the officers’ favor was affirmed.

3. Analysis

3.1 Precedents Cited and Their Influence

Graham v. Connor, 490 U.S. 386 (1989)
Established the “objective reasonableness” standard for Fourth-Amendment excessive-force claims. Glenn situates its analysis within that framework.
Nolin v. Isbell, 207 F.3d 1253 (11th Cir. 2000)
Key Eleventh-Circuit marker for what amounts to de minimis force. The court analogized the minor bruises in Nolin to A.G.’s bruising, deeming both insufficient for an excessive-force claim.
Croom v. Balkwill, 645 F.3d 1240 (11th Cir. 2011)
Allowed knee-to-back restraint of an elderly woman as de minimis where officers faced uncertain danger. Glenn relies on Croom’s emphasis on officer safety and “unquestioned command.”
Jones v. City of Dothan, 121 F.3d 1456 (11th Cir. 1997)
Upheld forceful frisk of an infirm man as de minimis; cited to show that plaintiff’s physical frailty—or youth—does not by itself transform minor force into excessive force.
Richmond v. Badia, 47 F.4th 1172 (11th Cir. 2022)
A rare case finding excessive force by an SRO against a student. The panel distinguished Richmond because the officer there had no law-enforcement purpose or safety threat; in Glenn, by contrast, the officers reasonably perceived an ongoing fight.
Pearson v. Callahan, 555 U.S. 223 (2009)
Articulated the two-step qualified-immunity inquiry—providing the structural roadmap for the court’s analysis.

3.2 Legal Reasoning in Depth

“Any force used by the officers was de minimis and, thus, A.G.’s constitutional rights were not violated.”

Key analytical moves:

Objective Reasonableness with Embedded “De Minimis” Filter. The panel treated the de minimis doctrine as a threshold screen: if the quantum of force is legally trivial, the constitutional inquiry ends.
Video Evidence. Following Scott v. Harris, 550 U.S. 372 (2007), the court privileged video footage over competing testimony, thereby resolving factual disputes in defendants’ favor when the tape contradicted plaintiff’s version.
Importance of Perceived Threat. Though the officers misread the situation (the students were stealing snacks, not fist-fighting), the court credited their mistaken but reasonable perception that a fight was underway. This perceived threat justified split-second, physically controlling measures.
Injury Severity as Proxy. The court implicitly used the extent of injury (bruises & soreness; no medical treatment beyond optional ibuprofen) as a metric for the amount of force applied.
Youth Not Dispositive. Glenn argued a 14-year-old’s vulnerability should lower the excessive-force bar. The panel disagreed, citing circuit and out-of-circuit authority that age alone does not convert minor force into a constitutional violation.

3.3 Likely Impact of the Decision

The precedential heft of Glenn lies not in a novel legal standard but in the factual nuance it adds to an established doctrine.

SRO Encounters. After Richmond, plaintiffs hoped the Eleventh Circuit might scrutinize school-based uses of force more closely. Glenn tempers that hope, signaling that ordinary Nolin/Croom analysis applies even in academic settings and even with minors.
Qualified Immunity Litigation. The opinion illustrates that courts may dispose of claims at the first prong—no constitutional violation—without reaching “clearly established” law, thereby avoiding expansion of the right. Future plaintiffs must marshal evidence of more than fleeting bruises.
Policy Ramifications. School districts may view the decision as validation of current SRO training emphasizing quick, physical intervention. Conversely, civil-rights advocates may push legislatures or school boards (rather than courts) to regulate SRO tactics when minors are involved.
Evidentiary Strategy. The court’s reliance on video underscores the critical importance of contemporaneous recordings. Plaintiffs will increasingly seek high-definition, multi-angle footage to capture subtle applications of force the panel deemed “unclear” here.

4. Complex Concepts Simplified

De Minimis Force: A quantity of force so slight that, even if every fact alleged by the plaintiff is true, the Constitution is not offended. Think of a gentle shove, momentary wrist-grip, or brief neck restraint leaving only transient redness.
Qualified Immunity: A legal shield protecting public officials from civil damages unless (1) they violated a constitutional right and (2) that right was “clearly established” so that every reasonable officer would have known the conduct was unlawful.
Objective Reasonableness: The touchstone for Fourth-Amendment force claims: would a reasonable officer, in the heat of the moment with the same information, think the force used was necessary?
Summary Judgment: A procedure allowing the court to decide a case without trial when no genuine dispute of material fact exists. All evidence is viewed in the non-movant’s favor—except when video “blatantly contradicts” that party’s story.
Split-Second Judgments: Courts give officers leeway for decisions made rapidly under tense conditions. Misperceptions (e.g., believing a theft melee is a fist-fight) are forgiven if reasonable.

5. Conclusion

Glenn v. Britt delivers a clear if controversial message: brief, physically controlling maneuvers by school resource officers—causing minor bruises—are constitutionally trivial, even when applied to minors. By reaffirming the sturdiness of the Eleventh Circuit’s de minimis force doctrine, the court simultaneously curtails §1983 exposure for officers and narrows litigants’ pathways to trial on school-based excessive-force claims. Unless the Supreme Court revamps qualified-immunity doctrine or Congress legislates otherwise, plaintiffs alleging school-house excessive force must now show more substantial injuries or a far clearer lack of justification to overcome the Eleventh Circuit’s fortified barrier.