Reasonableness of Minimal Force to Secure a Non-Compliant Suspect in the Patrol Car

Introduction

Jalen Bass v. Roland Jones, Jr. (No. 25-10261), decided May 29, 2025, by the United States Court of Appeals for the Eleventh Circuit, clarifies the boundary between de minimis force and excessive force under the Fourth Amendment when a handcuffed, non-resisting suspect refuses to obey an officer’s instructions.

Plaintiff‐Appellant Jalen Bass challenged his arrest by Officer Roland Jones, Jr., alleging that Officer Jones used excessive force in violation of the Fourth Amendment (42 U.S.C. § 1983) and committed state‐law assault and battery under Georgia law (Ga. Code Ann. §§ 51‐1‐13, 51‐1‐14). Bass claimed that Officer Jones shoved him into the backseat of a patrol car without warning, causing a head injury. The District Court granted summary judgment for Officer Jones, and Bass appealed.

Summary of the Judgment

The Eleventh Circuit unanimously affirmed. Viewing the body‐cam video and all evidence in Bass’s favor except where contradicted by the video, the Court held:

Officer Jones’s push into the rear seat of the patrol car was reasonable and de minimis given: Bass’s repeated refusal to obey lawful commands, the officer’s unaccompanied duty with a civilian passenger in the stopped vehicle, and the need to secure Bass for safety.
Qualified immunity applied because no clearly established case law would have put Officer Jones on notice that his conduct violated the Fourth Amendment.
Official immunity applied to the state‐law claims because the use of force was a discretionary act and Bass presented no evidence of actual malice or intent to injure.

Analysis

Precedents Cited

Brooks v. Miller, 78 F.4th 1267 (11th Cir. 2023) – Body‐cam footage may rebut a plaintiff’s facts when it “actually proves that the plaintiff’s version cannot be true.”
Richmond v. Badia, 47 F.4th 1172 (11th Cir. 2022) – Summary judgment is reviewed de novo, with all inferences in favor of the non‐movant.
Charles v. Johnson, 18 F.4th 686 (11th Cir. 2021) – Outlines the qualified‐immunity two‐step: (1) was the officer acting within discretionary authority? (2) did he violate a clearly established right?
Durruthy v. Pastor, 351 F.3d 1080 (11th Cir. 2003) – Even minor traffic offenses can justify some force in custodial arrest.
Zivojinovich v. Barner, 525 F.3d 1059 (11th Cir. 2008) – Use of a Taser on a handcuffed suspect who ignored commands was not excessive.
Patel v. City of Madison, Ala., 959 F.3d 1330 (11th Cir. 2020) – Dramatic leg sweep causing paralysis was excessive force.
Stephens v. DeGiovanni, 852 F.3d 1298 (11th Cir. 2017) – Slamming a compliant suspect against a vehicle door frame was excessive.
Lee v. Ferraro, 284 F.3d 1188 (11th Cir. 2002) – Head‐slamming of a non‐resisting suspect without justification violated the Fourth Amendment.

Legal Reasoning

The Court first determined Officer Jones was acting within his discretionary authority by conducting a lawful traffic stop and securing a potentially intoxicated driver. Under the Graham v. Connor framework, the Fourth Amendment’s “objective reasonableness” test applies. The relevant factors are:

Severity of the suspected offense (failure to stop at a red light).
Whether the suspect posed an immediate threat (refusal to obey, possible intoxication, passenger present).
Whether the suspect was actively resisting or attempting to flee (Bass ignored multiple commands).
Relationship between the need for force and the amount used (a single push to secure Bass in the car).
Extent of injury inflicted (Bass alleges a concussion, but force was a push, not a slam into metal bars).

The Court concluded that the push was proportional to the legitimate need to secure a non-compliant, handcuffed suspect. Citing Zivojinovich, it held that even handcuffed suspects may be subject to reasonable force when they ignore commands. Because the officer did not slam Bass’s head into metal, but merely pushed him into the rear seat, it was not excessive.

On qualified immunity, the Court found no controlling precedent clearly establishing that such a push would violate the Fourth Amendment. Thus, Officer Jones was entitled to immunity.

For the state‐law claims, Georgia’s official‐immunity doctrine shields officers from discretionary acts unless actual malice or intent to injure is shown. Placing Bass into the car involved judgment about safety and risk, and Bass offered no evidence of malice. The use‐of‐force policy did not impose a ministerial duty to warn, but left such warnings to officer discretion.

Impact

This decision reinforces that:

Brief, non‐violent shoves to secure a non‐compliant detainee ordinarily fall within de minimis force and will not support a Fourth Amendment claim.
Qualified immunity remains robust in situations where officers make split‐second decisions to maintain safety.
State‐law official immunity in Georgia continues to protect officers’ discretionary acts absent malice, even where departmental policies suggest best practices.

Future litigants must point to closely analogous precedent to overcome qualified immunity when force is minimal but contested.

Complex Concepts Simplified

Qualified Immunity: Shields officers from lawsuits unless they violated a constitutional right that was “clearly established” at the time.
Objective Reasonableness: Courts judge force from the viewpoint of a reasonable officer on the scene, not with hindsight.
De Minimis Force: Minor uses of force that cause little or no injury generally do not violate the Fourth Amendment.
Discretionary vs. Ministerial Acts: Discretionary acts involve judgment calls and are protected absent malice; ministerial acts are mandatory and unprotected if negligently performed.

Conclusion

Jalen Bass v. Roland Jones, Jr. underscores that a single push to place a recalcitrant, handcuffed suspect into a patrol car is reasonable under the Fourth Amendment and does not breach clearly established law. With this decision, the Eleventh Circuit provides law enforcement and courts a clear benchmark for distinguishing de minimis, lawful force from actionable excessive force in custodial settings.