Qualified Immunity Does Not Shield Gratuitous Force Once a Suspect Is Subdued: Ceinski v. Jones

Introduction

Jeremy Jones v. David Ceinski, Jr. is a pivotal Eleventh Circuit decision clarifying when law-enforcement officers can—and cannot—invoke qualified immunity in Fourth Amendment excessive‐force cases. In this 2025 ruling, the Court addressed the use of force by Officer David Ceinski against Jeremy Jones, who was stopped for a minor traffic infraction. Although Jones complied with every instruction and had been subdued, Ceinski choked and punched him while he was secured, triggering a § 1983 claim. The key issues were (1) whether the chokehold and punch amounted to objectively unreasonable force under the Fourth Amendment, and (2) whether Ceinski is entitled to qualified immunity because the right was not “clearly established.”

Plaintiff-Appellant: Jeremy Jones, a motorist with a severe hand deformity and concealed-carry permit.
Defendant-Appellee: Officer David Ceinski, Jr., Sarasota Police Department.

Summary of the Judgment

The Eleventh Circuit reversed the magistrate judge’s grant of summary judgment for Ceinski. Viewing the facts in the light most favorable to Jones, the Court held that:

1. Although an officer may use reasonable force to prevent a suspect from retrieving an unsecured firearm, the chokehold and punch deployed once Jones was fully subdued and could no longer access the weapon constituted excessive—and therefore unconstitutional—force.
2. The right to be free from gratuitous force once a suspect is under control was clearly established by prior Eleventh Circuit precedent; accordingly, qualified immunity did not shield Ceinski from liability for the chokehold and punch.

The Court reversed summary judgment and remanded for trial on the excessive‐force claim.

Analysis

1. Precedents Cited

The Court’s reasoning relied heavily on settled Fourth Amendment excessive-force jurisprudence:

• Graham v. Connor (490 U.S. 386, 1989): Established the “objective reasonableness” standard and the three‐factor inquiry (severity of the crime, threat to officer/public, resistance or flight).
• Jean-Baptiste v. Gutierrez (627 F.3d 816, 11th Cir. 2010): Held that officers may continue using force until an armed suspect is “fully secured,” but no further.
• Perez v. Suszczynski (809 F.3d 1213, 11th Cir. 2016): Clarified that once a firearm is recovered and the threat neutralized, deploying further force—especially deadly force—is unreasonable.
• Sebastian v. Ortiz (918 F.3d 1301, 11th Cir. 2019): Applied the same logic to nonlethal force, condemning gratuitous tightening of handcuffs on a disarmed suspect.
• Lee v. Ferraro (284 F.3d 1188, 11th Cir. 2002): Rejected a de minimis‐force defense when an officer slammed a handcuffed suspect’s head into a car trunk, emphasizing that severity of injury does not legitimize gratuitous force.

2. Legal Reasoning

The Court’s decision unfolded in two analytical stages:

1. Objective Reasonableness Under Graham
   • Officer Ceinski’s initial wrist‐grab, arm twist, and push were reasonable to prevent Jones—a compliant but armed motorist—from accessing his concealed firearm.
   • Once those maneuvers fully subdued Jones and removed any immediate threat, continuing force by choking and punching exceeded what the Fourth Amendment permits.
2. Qualified Immunity and “Clearly Established” Law
   • Under Eleventh Circuit precedent, it was beyond debate that “gratuitous force against a non-violent, non-resisting suspect under control” violates the Fourth Amendment.
   • No specialized case on chokeholds or punches was required; the principle was obvious from decisions like Hadley and Stephens.

3. Impact

This ruling underscores the bright‐line boundary between permissible and excessive force:

• Officers may lawfully use reasonable restraint to secure an armed suspect, but must cease any further force the moment the suspect is under control and no longer poses a weapon‐based threat.
• Police departments should update training to stress the “fully secured” cutoff point—continuing force thereafter risks constitutional liability.
• Future excessive‐force suits in this Circuit will cite Ceinski v. Jones when defendants claim qualified immunity for post‐subdual violence.

Complex Concepts Simplified

• Qualified Immunity: A legal doctrine protecting officers from lawsuits unless they violate a right that was “clearly established” at the time.
• Fourth Amendment Reasonableness: Assessed objectively by balancing the officer’s need for force against the suspect’s rights.
• “Fully Secured” Suspect: A person who is handcuffed, subdued, and cannot access weapons—any additional force against such a person is presumptively excessive.
• De minimis doctrine: The idea that trivial force might not amount to a constitutional violation—but Eleventh Circuit law rejects it when force is gratuitous and unnecessary.

Conclusion

Ceinski v. Jones establishes a clear, enforceable rule: once a suspect is subdued, disarmed, and under control, any additional force—be it a chokehold, punch, or other violence—is objectively unreasonable and violates the Fourth Amendment. Officers have fair warning of this boundary; qualified immunity does not apply when force persists beyond the moment a suspect no longer poses a weapon-based threat. This decision will guide law enforcement training, departmental policies, and future § 1983 litigation in the Eleventh Circuit.