Clarifying the “Prone-but-Uncuffed” Threshold:
Excessive-Force Parameters Re-Drawn in Roe v. Redmond & Maertz (11th Cir. 2025)

1. Introduction

In August 2020 Clay County (Florida) deputies attempted to arrest Travis Roe on a murder warrant. The arrest escalated from a vehicular pursuit to a physical confrontation on Roe’s parents’ driveway, leading to allegations that Deputies Clint Redmond and Mark Maertz kicked, pistol-whipped, tackled, punched, and applied knee pressure to Roe’s back and neck. When Roe sued under 42 U.S.C. §1983, the district court granted summary judgment on qualified-immunity grounds.

On appeal, the Eleventh Circuit delivered a nuanced opinion: it affirmed qualified immunity for most uses of force but vacated the judgment as to Maertz’s 34–37 punches delivered while Roe lay prone, motionless, and compliant. The Court drew a bright(er) line for “gratuitous force” on suspects who are prone but not yet handcuffed, holding that such force violates clearly established Fourth-Amendment rights when the suspect is no longer resisting or posing a threat.

2. Summary of the Judgment

• Deputy Redmond: Kick to knee and single pistol strike deemed reasonable; full qualified immunity affirmed.
• Deputy Maertz – Part 1: Tackle upheld as reasonable; knee pressure for ≈1 minute post-handcuff was de minimis. Qualified immunity affirmed.
• Deputy Maertz – Part 2: 34–37 punches to Roe’s head while he was face-down with arms outstretched constituted excessive and clearly established misconduct. Summary judgment vacated; case remanded for that claim.

3. Analysis

3.1 Precedents Cited and Their Influence

• Graham v. Connor, 490 U.S. 386 (1989) – Provided the basic “objective reasonableness” framework.
• Scott v. Harris, 550 U.S. 372 (2007) – Video evidence trumps plaintiff’s version if “blatantly contradicted.”
• Mobley v. Palm Beach Cnty., 783 F.3d 1347 (11th Cir. 2015) – Force permissible where suspect on ground still resists/withholds hands.
• Smith v. Mattox, 127 F.3d 1416 (11th Cir. 1997) – Breaking arm of prone, cooperative suspect held excessive.
• Acosta v. Miami-Dade Cnty., 97 F.4th 1233 (11th Cir. 2024) – Tasing/kicking subdued suspect unconstitutional; recognized “prone-but-uncuffed” protection.
• Sebastian v. Ortiz, 918 F.3d 1301 (11th Cir. 2019) – “Gratuitous and substantial injury” post-compliance is excessive.

The Court synthesized these cases to articulate a continuum: force may be severe while resistance persists (Mobley), but once the suspect ceases resistance—even uncuffed—gratuitous strikes violate clearly established law (Smith, Acosta, Sebastian).

3.2 Legal Reasoning

1. Qualified-Immunity Structure. Deputies acted within discretionary authority; burden shifted to Roe to show (a) constitutional violation and (b) clearly established law.
2. Force Segmentation. The Court meticulously separated each discrete use of force—kick, pistol strike, tackle, punches, knee pressure—measuring each against the Graham factors.
3. Video-Evidence Gatekeeping. Helicopter and security footage overrode Roe’s narrative where plainly inconsistent (e.g., denial of flight), but absence of clear footage on punching phase required accepting Roe’s sworn testimony.
4. “Prone-but-Uncuffed” Distinction. The Court acknowledged a doctrinal gap between handcuffed and merely subdued suspects. By holding that gratuitous repeated punches to a motionless, prone suspect violate clearly established rights, the panel closes much of that gap.
5. De Minimis Doctrine. Applying Nolin and Croom, the one-minute knee pressure with no permanent injury fell below the constitutional threshold.

3.3 Potential Impact

• Operational Guidance to Officers: Once a suspect’s resistance ceases and they are under physical control, continuing strikes—even before cuffs click—risk personal liability.
• Litigation Strategy: Plaintiffs can now invoke Roe as circuit authority for “prone-but-uncuffed” excessive-force claims; defense counsel must parse incidents into discrete time slices.
• Training & Policy: Law-enforcement agencies in the Eleventh Circuit should revise use-of-force curricula to emphasize immediate de-escalation upon compliance, irrespective of cuff status.
• Qualified-Immunity Jurisprudence: By crediting older precedents (Smith, Sebastian) to defeat qualified immunity, the Court signals that granular fact matches are unnecessary when a broad principle—no gratuitous force after compliance—is well rooted.

4. Complex Concepts Simplified

Qualified Immunity

A shield that protects government officials from money damages unless (1) they violated the Constitution, and (2) the violated right was already “clearly established” so every reasonable officer would know.

Clearly Established Law

The legal “fair warning” requirement. It can be satisfied by a case with similar facts, a broad constitutional rule, or conduct so obviously wrong that no precedent is needed.

Excessive Force under the Fourth Amendment

Force is unconstitutional if, judged from the perspective of a reasonable officer on the scene, it is objectively unreasonable in light of crime severity, danger, resistance, proportionality, and resulting injury.

PIT Maneuver

“Precision Immobilization Technique” – an intentional police collision with a fleeing vehicle to force it to stop.

De Minimis Force

Minimal, trivial force that the law treats as insufficient to constitute a constitutional violation (e.g., brief knee pressure causing no lasting injury).

5. Conclusion

Roe v. Redmond & Maertz refines the Eleventh Circuit’s excessive-force doctrine in three pivotal respects:

1. Affirms that reasonable kicks or single strikes can be permissible during a volatile, uncertain arrest of a dangerous felony suspect.
2. Confirms that repeated, gratuitous blows to a prone, compliant suspect—handcuffed or not—cross the constitutional line and are beyond qualified-immunity protection.
3. Classifies brief, non-injurious knee pressure post-handcuff as de minimis, maintaining a narrow safe harbor for standard control techniques.

Practically, the decision sends a clear message: the moment resistance ends, so should significant force. By articulating the “prone-but-uncuffed” threshold, the Court equips lower courts, officers, and litigants with sharper analytical tools, thereby enhancing both accountability and clarity in Fourth-Amendment policing standards.