Instantaneous Force and Qualified Immunity: Sindell v. Coach & the Eleventh Circuit’s Refined Boundaries on Failure-to-Intervene and Retaliation Claims

1. Introduction

On 19 August 2025 the United States Court of Appeals for the Eleventh Circuit decided Adam Sindell v. Latonya Coach, No. 24-13529, an unpublished but highly instructive opinion on the contours of qualified immunity for jail officers. The panel (Rosenbaum, Abudu & Wilson, JJ.) affirmed summary judgment in favor of two Houston County, Georgia, deputies—Latonya Coach and Jacob Cleckner—on claims of excessive force, failure to intervene, and First Amendment retaliation brought under 42 U.S.C. § 1983 by pre-trial detainee Adam Sindell.

The decision draws bright lines in three areas:

• How quickly an officer must act for the law to deem intervention “practically impossible.”
• When an officer’s mixed motives—some lawful, some arguably retaliatory—preserve qualified immunity.
• What a plaintiff must show to defeat immunity when relying on “broad principles” rather than factually on-point precedent.

2. Summary of the Judgment

The Eleventh Circuit, reviewing de novo, held:

1. Deputy Cleckner’s single-leg takedown of Sindell—who had defied a lockdown order and remained in the common area—did not violate any clearly established right. No case with “indistinguishable facts” or sufficiently specific principle prohibited the brief use of force.
2. Deputy Coach could not be liable for failure to intervene because the incident was too rapid for meaningful intervention.
3. Retaliation claims failed. Although Coach’s statements suggested animus toward Sindell for filing a grievance, her contemporaneous lawful motive (restoring order) preserved qualified immunity; Cleckner lacked any evidence of retaliatory motive at all.

Consequently, the district court’s grant of summary judgment on qualified immunity grounds was affirmed.

3. Analysis

3.1 Precedents Cited and Their Influence

• Kingsley v. Hendrickson, 576 U.S. 389 (2015) – Established the objective “reasonableness” test for pre-trial detainee force claims. Sindell invoked its broad principle; the panel found it too general to make Cleckner’s conduct “beyond debate.”
• Skrtich v. Thornton, 280 F.3d 1295 (11th Cir. 2002) – Held graceless force on a subdued prisoner violates the Eighth Amendment. Distinguished because force stopped once Sindell was cuffed.
• Danley v. Allen, 540 F.3d 1298 (11th Cir. 2008) – Force becomes unconstitutional when continued after the need dissipates. The panel used Danley to show Cleckner’s cessation of force met constitutional requirements.
• Jackson v. City of Atlanta, 97 F.4th 1343 (11th Cir. 2024) – Failure-to-intervene liability rare when force is “over quickly.” Provided the doctrinal bridge for absolving Coach.
• Stanley v. City of Dalton, 219 F.3d 1280 (11th Cir. 2000) – Qualified immunity survives when lawful motives partially drive the challenged act. Key to rejecting Sindell’s retaliation theory against Coach.
• Bailey v. Wheeler, 843 F.3d 473 (11th Cir. 2016) & Smith v. Mosley, 532 F.3d 1270 (11th Cir. 2008) – Set the three-part test for inmate-speech retaliation claims. Applied but causation prong failed.

3.2 Legal Reasoning

The court deployed the familiar two-step qualified-immunity framework:

1. Discretionary Function? Uncontested: deputies were acting within their discretionary jail duties.
2. Violation of Clearly Established Right? Plaintiff bears the burden. The court tackled “clearly established” first—if absent, analysis ends. Specific reasoning:
   • Excessive Force: Sindell lacked precedent “with indistinguishable facts.” Kingsley’s broad standard was insufficient because Sindell was non-compliant. The “obvious clarity” exception also failed as the takedown was neither gratuitous nor prolonged.
   • Failure to Intervene: Temporal impossibility barred liability. Under Jackson, the seconds-long encounter gave Coach no realistic chance to intercede.
   • Retaliation: (a) Coach – Mixed-motive doctrine: lawful need to enforce lockdown defeated claim. (b) Cleckner – No evidence he even knew about the grievance, so causation missing.

3.3 Likely Impact of the Decision

• Qualified Immunity Litigation: Sindell tightens the “obvious clarity” gateway; detainees must supply either on-point precedent or egregious, prolonged conduct. Brief, non-injurious takedowns remain immunized absent clear authority.
• Failure-to-Intervene Claims: The decision cements a de minimis temporal window requirement in the Eleventh Circuit: unless an officer has significant time and proximity, liability is unlikely.
• Retaliation Standards: Demonstrates that mixed motives and the absence of direct knowledge can derail First Amendment claims at the summary-judgment stage.
• Jail Management Practices: Confirms that officers may use proportionate force to regain control over lockdown-defying detainees without fear of personal liability, provided force ends once compliance is achieved.
• Pleading Strategy: Plaintiffs will need to allege detailed facts establishing (i) officers’ knowledge of protected speech, (ii) temporal opportunity to intervene, and (iii) absence of parallel lawful motives.

4. Complex Concepts Simplified

• Qualified Immunity (QI): A legal shield for public officials. Even if they violate the Constitution, they avoid personal liability unless they breach a “clearly established” right that every reasonable officer would know.
• Clearly Established Right: A standard met when (a) existing cases address materially similar facts, (b) a specific constitutional/ statutory text prohibits the conduct, or (c) the conduct is obviously egregious. Broad, general principles rarely suffice.
• Failure to Intervene: An officer present during another’s use of excessive force can be liable if she had both time and means to stop it and chose not to.
• Mixed-Motive Doctrine: Even if retaliation partly motivates an act, qualified immunity survives when an officer also had a legitimate, independent reason to act.
• Objective vs. Subjective Standards: Excessive-force claims under Kingsley are judged by what a reasonable officer would do (objective), while retaliation causation hinges on the actor’s actual motives (subjective).

5. Conclusion

Sindell v. Coach may be unpublished, but it speaks loudly in the Eleventh Circuit. The opinion:

1. Re-affirms that momentary, non-gratuitous force to secure compliance is shielded unless precedent squarely prohibits it.
2. Narrows failure-to-intervene liability to scenarios where officers have genuine, identifiable time and positional advantage.
3. Illustrates the evidentiary hurdles in inmate-retaliation suits, emphasizing the dual requirements of officer knowledge and minimal lawful motive.

For practitioners, the case is a reminder: when challenging officer conduct, specificity is paramount—both in pleading facts and in citing precedent. For correctional officials, it provides reassurance that swift, proportionate responses to rule violations remain within the protective ambit of qualified immunity, so long as they cease once order is restored.