Arbitrary Detention, Arguable Probable Cause, and De Minimis Force: The Eleventh Circuit’s Rule in Daniels v. Blakley

Introduction

In Terrell Daniels, Jr. v. Kadarius Blakley (11th Cir. May 28, 2025), the United States Court of Appeals for the Eleventh Circuit addressed two recurring Fourth Amendment questions: (1) whether officers who briefly detain and handcuff a misidentified suspect enjoy “arguable probable cause” for arrest, and (2) whether the minimal force used in a four-minute detention can give rise to an excessive-force claim.

Plaintiff‐Appellant Terrell Daniels, Jr., a Black man with dreadlocks, was arrested and handcuffed for under four minutes after a nursing‐home assault. Although a grainy video and a witness initially identified him as the assailant, a nurse on the way to the patrol car corrected the officers, leading to Daniels’s release. He sued under 42 U.S.C. § 1983 and Georgia state law for false arrest, excessive force, and related claims. The district court granted summary judgment to the officers on qualified immunity grounds. Daniels appealed, challenging (i) the lack of probable cause for arrest, and (ii) the use of force in taking him to the ground and handcuffing him.

Summary of the Judgment

The Eleventh Circuit affirmed. First, it held that when officers reasonably—but mistakenly—rely on a combination of an eyewitness identification, a video depicting a matching description, and the suspect’s on-scene conduct, they possess “arguable probable cause” to arrest. Second, it concluded that the mild physical force used—bringing Daniels to the ground and applying handcuffs for under a minute—was de minimis and objectively reasonable under Graham v. Connor. Because there was no Fourth Amendment violation, the officers were entitled to qualified immunity as a matter of law. The court also deemed state-law claims abandoned on appeal.

Analysis

Precedents Cited

• Terry v. Ohio, 392 U.S. 1 (1968) – Established the distinction between an investigative stop (requiring reasonable suspicion) and a full arrest (requiring probable cause).
• Pearson v. Callahan, 555 U.S. 223 (2009) – Permits courts to decide qualified immunity by addressing either the constitutional violation or whether the right was clearly established.
• Case v. Eslinger, 555 F.3d 1317 (11th Cir. 2009) – Defined “arguable probable cause”: officers are immune if a reasonable officer could have believed that probable cause existed.
• United States v. Acosta, 363 F.3d 1141 (11th Cir. 2004) – Outlined factors (scope, intrusiveness, purpose) distinguishing a Terry stop from an arrest.
• Graham v. Connor, 490 U.S. 386 (1989) – Set forth the objective-reasonableness standard for excessive-force claims under the Fourth Amendment.
• Vinyard v. Wilson, 311 F.3d 1340 (11th Cir. 2002) – Instructed courts to consider the need for force, the relationship between need and force, and the extent of injury.
• Durruthy v. Pastor, 351 F.3d 1080 (11th Cir. 2003) – Recognized that de minimis force in effecting an arrest cannot support a Fourth Amendment excessive‐force claim.
• Nolin v. Isbell, 207 F.3d 1253 (11th Cir. 2000) – Confirmed that “de minimis” contact, without more, is not unconstitutional.

Legal Reasoning

1. Arguable Probable Cause for Arrest
The court treated Daniels’s handcuffing and escort toward the patrol car as a full arrest under Acosta, not a Terry stop. Probable cause exists if, under the totality of the circumstances, officers reasonably believe the suspect committed an offense. Even if the belief is mistaken, “arguable probable cause” suffices for qualified immunity (Eslinger).

Here, officers responded to a call describing a Black male with dreadlocks assaulting nursing‐home staff. Daniels matched that description, appeared on the scene shouting, and was positively identified by a Gracemore employee from a blurry cellphone video showing someone with dreadlocks kicking staff. Although the ID proved incorrect, no reasonable officer would have known that at the time. Thus, probable cause was at least arguable.

2. Excessive‐Force Claim
Under Graham, courts judge force by an objective-reasonableness standard, balancing:

• the need for force;
• the relationship between that need and the force used; and
• the extent of the injury inflicted (if any).

When Officer Blakley ordered Daniels to place his hands behind his back, Daniels stiffened. To complete the arrest, officers took him to the ground, applied pressure across his torso and legs, and handcuffed him. The entire episode lasted under a minute on the ground and four minutes in handcuffs. There were no strikes, injuries, or weapons. Consistent with Durruthy and Nolin, this de minimis force was reasonable.

Impact

• Qualified Immunity Reinforced: Officers making split-second decisions based on imperfect information remain shielded so long as their belief in probable cause is reasonable.
• De Minimis Force Doctrine: A reaffirmation that minor, non‐injurious force to secure compliance—even if later shown unnecessary—does not violate the Fourth Amendment.
• Plaintiff Pleading Standards: The opinion underscores the importance of coherent briefing and precise citation. Courts may deem poorly developed arguments abandoned.
• Practical Policing Guidance: Officers may rely on video evidence and eyewitness identification—even if of poor quality—when deciding to effect an arrest.

Complex Concepts Simplified

Arguable Probable Cause: Even if an arrest turns out to be for the wrong person, officers have immunity if a reasonable officer in the same situation could have believed there was probable cause.

Qualified Immunity: A legal shield for government officials that bars claims unless they violated a clearly established statutory or constitutional right.

Terry Stop vs. Arrest:

• A Terry stop is a brief, investigatory detention (you’re stopped, not cuffed).
• An arrest is more intrusive: you are handcuffed, told you’re going to jail, and moved toward a patrol car.

De Minimis Force: Trivial or minimal force that causes no injury—such as a light takedown or cuffing—is not excessive under the Fourth Amendment.

Conclusion

Daniels v. Blakley reaffirms two bedrock Fourth Amendment principles: (1) officers acting on reasonable but mistaken information enjoy qualified immunity through the “arguable probable cause” doctrine, and (2) minimal, non‐injurious force to secure an arrest is constitutionally permissible. This decision bolsters law‐enforcement confidence in split‐second assessments while clarifying plaintiffs’ burden to articulate coherent, well‐supported claims.