1. Introduction

Nancy Hooks v. City of Warren, Mich. (6th Cir., May 30, 2025) arises from an April 2019 street-corner incident in Warren, Michigan, in which 57-year-old Nancy Hooks stopped to assist the victim of a teenage street fight and then was forcibly tackled, handcuffed, jailed, acquitted of state “hindering” charges, and sued the responsible officers and municipal defendants under 42 U.S.C. § 1983 and Michigan law. The district court granted summary judgment in part but denied qualified immunity to Officers Doe and Munafo on Hooks’s excessive-force and unlawful-arrest claims, and allowed related state-law claims for battery, malicious prosecution, and intentional infliction of emotional distress to proceed. The officers appealed the denial of immunity; the Sixth Circuit sua sponte dismissed the appeal for lack of appellate jurisdiction under the collateral-order doctrine.

2. Summary of the Judgment

The Sixth Circuit held that an interlocutory appeal of the denial of qualified immunity is permissible only on purely legal issues. Where the denial turns on disputed material facts or on disputed inferences drawn from those facts, the court lacks jurisdiction under 28 U.S.C. § 1291. Here, disputed factual questions—whether Hooks was complying with officers’ commands when arrested and whether her reflexive arm-raise could reasonably be interpreted as resisting arrest—prevented the Court from reviewing the district court’s denial of immunity on the unlawful-arrest and excessive-force claims. Because no “blatantly contradicted” video evidence nor genuine concession from the officers resolved those disputes, the appellate court dismissed the appeal. It further declined pendent jurisdiction over the related Michigan tort claims.

3. Analysis

3.1. Precedents Cited

• Johnson v. Jones (515 U.S. 304, 1995): Denial of summary judgment on factual disputes over qualified immunity is not directly appealable.
• Estate of Carter v. City of Detroit (408 F.3d 305, 2005): Only “purely legal” rulings on qualified immunity are appealable; fact‐based disputes must await final judgment.
• Barry v. O’Grady (895 F.3d 440, 2018): Reinforced that appeals of qualified‐immunity denials may proceed only when legal questions predominate and facts are undisputed or conceded.
• Scott v. Harris (550 U.S. 372, 2007): Video evidence that “blatantly contradicts” the nonmovant’s version can be credited over their testimony at summary judgment.
• Gillispie v. Miami Township (18 F.4th 909, 2021): Where disputed facts underlie immunity denials, appellate jurisdiction is lacking.

3.2. Legal Reasoning

Qualified immunity shields government officials from suit unless (1) the official violated a constitutional right and (2) the right was clearly established at the time. Under the collateral‐order doctrine, a denial of qualified immunity is immediately appealable only “to the extent” it presents a legal question. When a denial rests on unresolved factual disputes or on contested inferences, appellate courts must dismiss for lack of jurisdiction.

Here, the district court viewed the two videos (a dashcam and a bystander’s cellphone recording) in the light most favorable to Hooks. It found genuine disputes over whether she was obeying commands and whether her arm movement was a reflex or an attempt to resist. These disputes were “crucial” to both the unlawful‐arrest and excessive‐force analyses. Because the officers’ appeal hinged on their version of those facts—and because the videos neither “blatantly and demonstrably” contradicted Hooks’s version nor did the officers genuinely concede her version—the Sixth Circuit concluded it lacked authority to review the immunity rulings.

3.3. Impact

This decision reinforces strict limits on interlocutory appeals of qualified immunity in the Sixth Circuit. It underscores that:

• Officers cannot “fact-shop” at the appellate level: any genuine dispute of material fact must be resolved first in the district court.
• Video evidence will only overcome a plaintiff’s version if it “blatantly contradicts” that version, leaving no room for reasonable disagreement.
• Mere disagreement with the inferences drawn by the district court is insufficient to sustain an interlocutory appeal.

Future § 1983 litigants in this circuit must ensure that all critical factual disagreements are narrowed or resolved below before seeking appellate review of immunity denials.

4. Complex Concepts Simplified

Qualified Immunity

A defense that protects government officials from lawsuits if their alleged misconduct did not violate “clearly established” law of which a reasonable officer would have known.

Collateral-Order Doctrine

An exception to the “final judgment” rule allowing immediate appeal of certain decisions (like qualified immunity) that are conclusive, separate from the merits, and effectively unreviewable later.

Interlocutory Appeal

An appeal taken before the district court has entered a final, substantive ruling on all claims.

Blatantly Contradicted

A standard (from Scott v. Harris) meaning that video or other concrete evidence so clearly disproves a party’s testimony that no reasonable jury could credit it.

5. Conclusion

Nancy Hooks v. City of Warren clarifies that the Sixth Circuit will not review interlocutory denials of qualified immunity when key facts remain in dispute or when the appellate arguments depend on contested inferences. Only purely legal rulings—where the material facts are undisputed or blatantly contradicted—are immediately appealable. This decision preserves the district court’s fact‐finding role and ensures that immunity disputes based on factual disagreements are resolved only after full development of the record.