Reaffirming the Limits of Force: No Qualified Immunity for Post-Handcuff Strikes on a Non-Resisting Suspect

Case: Albert Lee St. Clair, Jr. v. DeAngelo M. Anthony, et al. (No. 24-11302)
Court: U.S. Court of Appeals for the Eleventh Circuit (Non-Argument Calendar; Not for Publication)
Panel: Circuit Judges Luck, Lagoa, and Wilson (per curiam)
Date: September 2, 2025
Disposition: Affirmed (denial of qualified immunity on excessive force claims)

Introduction

This appeal arises from a high-speed pursuit and foot chase in Lakeland, Florida, culminating in the arrest of Albert Lee St. Clair, Jr. After officers disabled the stolen vehicle and a police canine brought St. Clair to the ground, a brief but violent struggle ensued. St. Clair alleges that once he was face down, handcuffed, and had ceased resisting, multiple officers continued to strike, kick, and baton him—conduct he says was unconstitutional “gratuitous force.”

Seven officers—DeAngelo Anthony, Derek Gulledge, Aaron Peterman, Zachary Simmons, Eric Strom, Justin King, and Nicholas Rex—interlocutorily appealed the district court’s denial of qualified immunity at summary judgment as to St. Clair’s excessive force claims. The Eleventh Circuit affirmed. The court held that, taking the facts in the light most favorable to the plaintiff, a reasonable jury could find the officers used excessive force after St. Clair had been subdued, and that it was clearly established by 2019 that gratuitous force against a non-resisting suspect is unconstitutional.

Summary of the Judgment

• Jurisdiction: The court had interlocutory jurisdiction because the appeal raised legal issues—how to apply the objective reasonableness standard and how to frame the clearly established right—rather than purely evidentiary sufficiency questions.
• Excessive Force (Prong One): Applying the Graham/Mobley factors, the court agreed that—on the plaintiff’s account—force continued for roughly 15 seconds after St. Clair was face down, handcuffed, and had stopped resisting. Even acknowledging the serious crimes and risky pursuit, continued strikes after restraint could be found objectively unreasonable.
• Clearly Established Law (Prong Two): By April 2019, Eleventh Circuit law clearly prohibited gratuitous force against a non-resisting, subdued suspect. The court relied on the “broad principle” pathway to clearly established law rather than requiring materially identical precedent.
• Result: The denial of qualified immunity at summary judgment was affirmed for all seven officers.

Detailed Analysis

Procedural Posture and Factual Framing

The district court granted summary judgment on all claims except the excessive force claims against the seven officers. As required at the summary judgment stage, it credited St. Clair’s version of disputed facts: that after initial takedown, he surrendered, ceased resisting, and was handcuffed within seconds, yet officers continued to strike him for approximately 15 seconds. No body-worn or dash camera captured the specific use-of-force sequence; thus, there was no video that eliminated the factual dispute. The Eleventh Circuit adopted that same plaintiff-favorable lens on appeal.

Precedents Cited and Their Influence

• Ellis v. England, 432 F.3d 1321 (11th Cir. 2005); Stryker v. City of Homewood, 978 F.3d 769 (11th Cir. 2020); Stephens v. DeGiovanni, 852 F.3d 1298 (11th Cir. 2017):
  These cases underscore the summary judgment rule: courts must view the facts in the light most favorable to the nonmovant and accept the plaintiff’s account unless conclusively contradicted by the record. Here, with no dispositive video and disputed testimony, the court credited St. Clair’s account of post-handcuff force.
• English v. City of Gainesville, 75 F.4th 1151 (11th Cir. 2023); Cottrell v. Caldwell, 85 F.3d 1480 (11th Cir. 1996):
  These decisions delineate interlocutory appellate jurisdiction in qualified immunity appeals. The Eleventh Circuit reaffirmed that it may review legal and mixed questions but not pure evidentiary sufficiency. The officers’ challenges fit the legal category (perspective of a reasonable officer; defining the clearly established right).
• Hadley v. Gutierrez, 526 F.3d 1324 (11th Cir. 2008); Holloman ex rel. Holloman v. Harland, 370 F.3d 1252 (11th Cir. 2004):
  Classical statements of the qualified immunity framework and the plaintiff’s burden once the defendant shows discretionary authority.
• Graham v. Connor, 490 U.S. 386 (1989):
  The cornerstone excessive force standard—objective reasonableness under the totality of circumstances, mindful of split-second judgments.
• Baxter v. Santiago-Miranda, 121 F.4th 873 (11th Cir. 2024); Baker v. City of Madison, 67 F.4th 1268 (11th Cir. 2023); McCullough v. Antolini, 559 F.3d 1201 (11th Cir. 2009); Oliver v. Fiorino, 586 F.3d 898 (11th Cir. 2009):
  These decisions elaborate on balancing risks versus perceived threats and applying objective reasonableness. They inform the lens through which the court evaluated the officer conduct at the critical time force was used.
• Mobley v. Palm Beach County Sheriff’s Dep’t, 783 F.3d 1347 (11th Cir. 2015):
  Provides a six-factor framework consistent with Graham—severity of crime, immediate threat, active resistance/flight, need for force, proportionality, and injury.
• Acosta v. Miami-Dade County, 97 F.4th 1233 (11th Cir. 2024):
  Central to the analysis. Acosta emphasizes temporal focus: threat and resistance must be assessed at the time the force at issue is applied, not earlier in the encounter. Once a suspect is subdued and no longer resisting, additional tases or kicks are excessive. The court relied on Acosta to reject the officers’ attempt to justify later blows by pointing to danger earlier in the encounter.
• Ingram v. Kubik, 30 F.4th 1241 (11th Cir. 2022); Saunders v. Duke, 766 F.3d 1262 (11th Cir. 2014); Stryker v. City of Homewood, 978 F.3d 769 (11th Cir. 2020):
  These decisions articulate the clearly established principle that “gratuitous use of force when a criminal suspect is not resisting arrest constitutes excessive force.” They supply the broad statement of law the court used to defeat qualified immunity’s second prong.
• Prosper v. Martin, 989 F.3d 1242 (11th Cir. 2021):
  Explains the three recognized routes to show clearly established law: materially similar case law, a broad principle, or obvious clarity. The court used the “broad principle” route here.

Legal Reasoning

1) Interlocutory Jurisdiction

Although plaintiffs often argue that defendants’ appeals from denials of qualified immunity are fact-bound and thus beyond interlocutory jurisdiction, the court found jurisdiction here because the officers framed legal issues: whether the district court properly applied the “reasonable officer on the scene” perspective and whether it stated the clearly established right at the correct level of specificity. That is enough to permit appellate review at this stage.

2) Constitutional Violation (Objective Reasonableness)

The court walked through the Mobley/Graham factors, expressly from the vantage point of a reasonable officer at the precise moment force was used:

• Severity of Crime: This weighed for the officers. St. Clair stole a city truck, led a dangerous, prolonged chase, and committed multiple felonies. Gravity matters.
• Immediate Threat: Critically, the measure is the threat when the strikes occurred—not earlier. On the plaintiff’s account, he was face down, handcuffed, and shouting that officers were “killing” him when the blows continued. At that point a reasonable officer would not perceive an immediate threat. This factor weighed for the plaintiff.
• Active Resistance/Flight: Whatever resistance existed vanished once St. Clair was restrained on the ground in handcuffs. Continued blows after that moment cut against reasonableness. This factor favored the plaintiff.
• Need for Force and Proportionality: These twin considerations “travel together.” Even if initial force to subdue was justified, the need abated once restraint was achieved; continued strikes lacked a legitimate force-need and could be found disproportionate. Both factors favored the plaintiff.
• Injury: Although medical records immediately after the arrest did not document all injuries claimed (e.g., broken nose, lost teeth), the court accepted plaintiff’s sworn account at this stage, noting it was not irreconcilable with the records and video context. On that testimony, injuries were significant; this factor tilted toward the plaintiff.

Weighing all factors and the totality of circumstances, the court agreed with the district court: a reasonable jury could find the officers used excessive force by continuing to strike a handcuffed, non-resisting suspect for roughly 15 seconds after restraint. The panel rejected the argument that the chaotic pursuit justified continued post-restraint force, citing Acosta’s temporal segmentation requirement. It also rejected the contention that the plaintiff’s subjective intent to surrender was unknowable; what matters is what a reasonable officer would perceive once the suspect is restrained and non-resisting.

Notably, a footnote addressed arguments that certain officers (Strom and Peterman) did not “strike” St. Clair. The court observed there was record evidence they applied force (controlling legs; force to arm and hand). The question is not the label placed on the act, but whether the force used—of any type—was excessive under Graham at the time it was applied.

3) Clearly Established Law

The court endorsed the district court’s reliance on the Eleventh Circuit’s broad, well-settled principle: an officer may not use gratuitous force against a suspect who is not resisting. By 2014 at the latest—and thus by 2019 for this arrest—decisions like Saunders, Stryker, and (in retrospect) Ingram and Acosta cemented the rule. The panel rejected the officers’ attempt to narrow the principle by recharacterizing their conduct as non-gratuitous. Taking the plaintiff’s facts as true, the force was gratuitous, and the governing principle sufficed to clearly establish the law without a need for near-identical facts.

Impact and Practical Significance

• Temporal Segmentation of Force Use:
  The decision reinforces that reasonableness is time-specific. Officers cannot bootstrap earlier danger or resistance to justify later force after the suspect is restrained. Courts will examine each discrete application of force at the moment it occurs.
• Post-Handcuff Force Scrutiny:
  Even brief windows matter. Approximately 15 seconds of continued blows after handcuffing can support a constitutional violation. Training and policies must emphasize immediate de-escalation once control is achieved.
• Clearly Established Law via Broad Principle:
  Defendants cannot always avoid liability by demanding a case with “indistinguishable” facts. In the Eleventh Circuit, the prohibition on gratuitous force against a non-resisting suspect is sufficiently specific to defeat qualified immunity in a range of post-restraint scenarios.
• Evidentiary Posture at Summary Judgment:
  Absent video conclusively disproving the plaintiff’s account, courts will credit the plaintiff’s testimony regarding both the sequence of force and injuries, even where initial medical records are incomplete or limited by circumstances (e.g., inability to remain still for scans). Defense counsel should not expect summary judgment to resolve competing narratives without incontrovertible record evidence.
• Interlocutory Appeals—Framing Matters:
  Appellate jurisdiction exists where appellants identify legal application errors (perspective, governing standard, clearly established framing). Defense counsel should frame issues accordingly; plaintiffs should anticipate appellate review of legal, not factual, disputes.
• Persuasive Value:
  Though unpublished and thus non-binding, the opinion is consistent with published Eleventh Circuit authority and will likely be cited persuasively in Florida, Georgia, and Alabama trial courts. It aligns with the circuit’s recent trajectory (e.g., Acosta) limiting post-restraint force.
• Multi-Officer Incidents:
  The ruling implicitly cautions that each officer’s discrete use of force will be evaluated. Controlling a suspect’s limbs, canine contact, and distraction blows all fall within the analysis; exertions not labeled as “strikes” can still be excessive if applied after resistance ends.

Complex Concepts Simplified

• Qualified Immunity:
  A shield for officials sued for damages. Plaintiffs must show both a constitutional violation and that the violated right was clearly established at the time. If either fails, the officer is immune.
• Clearly Established Law:
  Plaintiffs can meet this by pointing to (1) materially similar case law, (2) a clear, broadly stated legal principle that applies with obvious clarity to the facts, or (3) conduct so egregious that any reasonable officer would know it is unconstitutional.
• Objective Reasonableness (Graham v. Connor):
  Force is judged from the perspective of a reasonable officer on the scene, not with 20/20 hindsight, considering severity of crime, immediate threat, resistance/flight, need for force, proportionality, and injuries.
• Gratuitous Force:
  Force that serves no legitimate law enforcement purpose because the suspect is already subdued and not resisting. It is constitutionally excessive.
• Interlocutory Appeal:
  An appeal taken before the case is final. In the qualified immunity context, defendants may immediately appeal denials raising legal issues, but not pure disputes over whose facts to believe.
• Per Curiam; Non-Argument Calendar; Not for Publication:
  “Per curiam” means the opinion is issued in the court’s name without a single identified author; “Non-Argument Calendar” means decided without oral argument; “Not for Publication” means the opinion is non-precedential (not binding), though it may be cited as persuasive authority under circuit rules.
• Nolo Contendere:
  A plea in which the defendant does not contest the charges. While relevant background, such a plea does not automatically bar an excessive force claim where the claim does not necessarily impugn the validity of the conviction.

Key Takeaways

• Once a suspect is handcuffed, face down, and not resisting, continued strikes are likely unconstitutional. The need for force abates with restraint.
• Courts will assess the suspect’s threat level at the time each use of force occurs; danger earlier in an encounter does not justify later force after control is achieved.
• By 2019, it was clearly established in the Eleventh Circuit that gratuitous force against a non-resisting suspect violates the Fourth Amendment; officers are not entitled to qualified immunity for such conduct.
• On interlocutory appeal, defendants may challenge legal applications of standards and the formulation of clearly established rights, but cannot relitigate pure factual disputes.
• Injury evidence at summary judgment is evaluated in the light most favorable to the plaintiff unless the record conclusively contradicts it; incomplete early medical documentation does not, by itself, defeat a claim.

Conclusion

The Eleventh Circuit’s unpublished decision in St. Clair v. Anthony squarely reinforces a fundamental Fourth Amendment boundary: force justified to subdue a fleeing suspect does not remain justified once the suspect is handcuffed and non-resisting. The court’s reliance on Acosta’s temporal segmentation and on the well-settled “no gratuitous force” principle reaffirms that the clearly established law in this circuit has meaningful bite. For law enforcement agencies, the opinion underscores the importance of immediate de-escalation post-restraint and careful documentation of resistance at the exact moments force is applied. For litigants and trial courts, it offers a clear roadmap for analyzing excessive force at summary judgment, emphasizing the time-specific nature of reasonableness and the sufficiency of broad, settled principles to defeat qualified immunity in post-restraint force cases.

Cited Authorities (as referenced in the opinion)

• Graham v. Connor, 490 U.S. 386 (1989)
• Ellis v. England, 432 F.3d 1321 (11th Cir. 2005)
• English v. City of Gainesville, 75 F.4th 1151 (11th Cir. 2023)
• Cottrell v. Caldwell, 85 F.3d 1480 (11th Cir. 1996)
• Hadley v. Gutierrez, 526 F.3d 1324 (11th Cir. 2008)
• Holloman ex rel. Holloman v. Harland, 370 F.3d 1252 (11th Cir. 2004)
• Baxter v. Santiago-Miranda, 121 F.4th 873 (11th Cir. 2024)
• Oliver v. Fiorino, 586 F.3d 898 (11th Cir. 2009)
• Baker v. City of Madison, 67 F.4th 1268 (11th Cir. 2023)
• McCullough v. Antolini, 559 F.3d 1201 (11th Cir. 2009)
• Stryker v. City of Homewood, 978 F.3d 769 (11th Cir. 2020)
• Stephens v. DeGiovanni, 852 F.3d 1298 (11th Cir. 2017)
• Mobley v. Palm Beach County Sheriff’s Dep’t, 783 F.3d 1347 (11th Cir. 2015)
• Acosta v. Miami-Dade County, 97 F.4th 1233 (11th Cir. 2024)
• Ingram v. Kubik, 30 F.4th 1241 (11th Cir. 2022)
• Prosper v. Martin, 989 F.3d 1242 (11th Cir. 2021)
• Saunders v. Duke, 766 F.3d 1262 (11th Cir. 2014)