Teetz v. Stepien: The Tenth Circuit Brands Prolonged Prone Restraint of a Subdued Detainee as “Deadly Force”

Introduction

In Teetz v. Stepien, the U.S. Court of Appeals for the Tenth Circuit delivered one of the most consequential excessive-force rulings since Weigel v. Broad (2008). The case arises from the death of 17-year-old Cedric Lofton, who suffered cardiac arrest after being held in a prone (face-down) restraint for roughly forty minutes inside the Sedgwick County Juvenile Intake & Assessment Center (JIAC) in Wichita, Kansas. Lofton’s estate, represented by his brother Marquan Teetz, sued five corrections officers under 42 U.S.C. § 1983 for excessive force, failure to intervene, and related state-law torts. The District Court denied the officers’ qualified-immunity motion, and the officers took an interlocutory appeal.

The Tenth Circuit affirmed, holding that:

• A prolonged prone restraint employed after a suspect has been effectively subdued constitutes deadly force.
• Such force is clearly unconstitutional unless the suspect poses an immediate threat of serious physical harm.
• The “blatant-contradiction” exception to appellate deference on factual findings is narrow and inapplicable where video evidence is merely inconclusive.

Beyond resolving the immediate dispute, the judgment erects a robust precedent that will govern policing practices, custodial-care protocols, and qualified-immunity analyses within the Tenth Circuit and, likely, across the nation.

Summary of the Judgment

1. Jurisdiction & Scope of Review. The appellate panel (Judges McHugh, Eid, and Federico) emphasized its limited role in interlocutory qualified-immunity appeals—namely, to review only legal questions unless the District Court’s fact findings are “blatantly contradicted” by the record (Scott v. Harris standard).
2. Facts Deemed Undisputed for Appeal. The court accepted the District Court’s key finding that a reasonable jury could conclude Lofton stopped resisting during long “stagnant” periods while officers maintained pressure on his back, legs, and arms.
3. Blatant-Contradiction Rejected. The surveillance video was deemed inconclusive; therefore, defendants could not invoke the exception to revisit factual findings.
4. Constitutional Analysis. Applying Graham v. Connor, the panel held that once Lofton was effectively restrained, the continued prone hold—lasting roughly 30 minutes—was objectively unreasonable. That conduct qualifies as deadly force under Weigel and Estate of Booker v. Gomez.
5. Clearly Established Right. Pre-existing Tenth Circuit precedent (especially Weigel, Booker, and Lynch) clearly alerted officers that maintaining weight on a detainee’s back in the prone position after control is gained risks positional asphyxia and violates the Fourth Amendment.
6. Result. The panel affirmed the denial of qualified immunity and remanded for further proceedings.

Analysis

1. Precedents Cited and Their Influence

• Graham v. Connor, 490 U.S. 386 (1989)
  Provides the canonical three-factor “objective reasonableness” test (severity of crime, immediate threat, resistance/flight).
• Scott v. Harris, 550 U.S. 372 (2007)
  Created the “blatant-contradiction” doctrine. Here, the Tenth Circuit clarifies that testimonial disputes—especially between a deceased victim’s estate and defendant officers—rarely meet Scott’s stringent standard.
• Weigel v. Broad, 544 F.3d 1143 (10th Cir. 2008)
  First Tenth Circuit case labeling prolonged prone restraint on a handcuffed, subdued suspect as excessive and “deadly force.” Teetz extends Weigel by (i) treating a thirty-minute restraint as per se deadly force and (ii) applying it in a custodial rather than roadside setting.
• Estate of Booker v. Gomez, 745 F.3d 405 (10th Cir. 2014)
  Involved 142.5 lbs. placed on a prone, handcuffed inmate for ~3 minutes. Teetz magnifies Booker’s import by stressing duration (here ~30 minutes) and the presence of multiple officers.
• Pahls v. Thomas, 718 F.3d 1210 (10th Cir. 2013) & Lewis v. Tripp, 604 F.3d 1221 (10th Cir. 2010)
  Define limits on appellate factual review in qualified-immunity interlocutory appeals. The panel relies heavily on these cases to refuse defendants’ invitation to re-weigh evidence.
• Barnes v. Felix, 598 U.S. ___ (2025)
  Recent SCOTUS clarification that “totality-of-circumstances” analysis has no time limit; earlier events inform later force decisions. The Tenth Circuit leans on Barnes to evaluate the entire 40-minute encounter, not just the initial struggle.

2. The Court’s Legal Reasoning

The opinion follows a rigorous two-stage qualified-immunity inquiry:

1. Constitutional Violation
   • Under the Graham framework, only the first factor (felony battery) favored the officers.
   • Factors two and three flipped once Lofton ceased active resistance; five officers plus leg shackles eliminated any imminent threat or flight risk.
   • The court elevated the case to a “deadly force” analysis, reasoning that positional asphyxia is inherently lethal and prolonged prone holds are comparable to firearm use in constitutional gravity.
2. Clearly Established Law
   • Weigel and Booker had long warned officers that maintaining weight on a restrained suspect’s back can kill.
   • The fact-bound nuances (juvenile, mental-health crisis, length of restraint) only strengthen—not weaken—notice to officers.
   • Defendants’ reliance on an unpublished 2007 decision (Giannetti) was discounted; published authority controlled.

The court additionally rebuffed two doctrinal escape routes offered by defendants:

• “Blatant Contradiction” Exception – Surveillance video was inconclusive; thus, it did not override district-court fact finding.
• “Legal-Error-Leading-to-Fact-Error” Exception – The district court correctly applied law, so no de novo factual review was warranted.

3. Impact of the Judgment

a) Law-Enforcement Training & Policy
• Agencies must treat prone holds exceeding a brief stabilization period as deadly-force events—triggering heightened policy checks (command authorization, reporting, after-action review).
• Corrections, juvenile, and mental-health facilities face increased liability if standard operating procedures do not require officers to transition detainees off their stomachs promptly once resistance ceases.
• De-escalation and mental-health crisis protocols gain renewed urgency; 40-minute prone restraints are functionally outlawed under the Fourth Amendment in the Tenth Circuit.

b) Qualified-Immunity Litigation
• Plaintiffs will cite Teetz to pierce qualified-immunity defenses whenever officers maintain prone pressure past the “control point.”
• The ruling narrows defense counsel’s ability to invoke the “blatant-contradiction” pathway when video evidence is partial, silent, or ambiguous.

c) Broader Constitutional Jurisprudence
• Reinforces a circuit split—favorable to plaintiffs—on when positional asphyxia crosses into deadly-force territory.
• Complements SCOTUS’s 2025 pronouncements in Barnes by explicitly applying “no time limit” reasoning to a custodial setting.
• Could influence national standards for youth detention centers and spur DOJ Civil Rights Division investigations under the Civil Rights of Institutionalized Persons Act (CRIPA).

Complex Concepts Simplified

• Qualified Immunity – A legal shield for government officials, protecting them unless (1) they violate a constitutional right and (2) that right was “clearly established” at the time.
• Prone Restraint – Holding a person face-down, usually with weight on the back and limbs controlled; risky because it can impede breathing (positional asphyxia).
• Deadly Force – Force that carries a substantial risk of causing death (not just firearms; here, extended prone restraint).
• Blatant-Contradiction Doctrine – Appellate rule allowing courts to override lower-court fact findings only when video or documentary proof irrefutably disproves them.
• S.A.F.E. Holds – A wrist-control technique designed to immobilize without pain, typically part of juvenile-detention training curricula.
• Positional Asphyxia – Suffocation caused by positioning that limits chest expansion and airway patency; exacerbated by body weight placed on the back.

Conclusion

The Tenth Circuit’s opinion in Teetz v. Stepien crystallizes an essential Fourth-Amendment rule: once a detainee is under control, continued prone restraint with body weight is deadly force and presumptively unconstitutional. The decision also tightens the guardrails on the “blatant-contradiction” exception, ensuring that factual disputes grounded in partial video evidence remain the province of the jury. Going forward, law-enforcement and custodial agencies within the circuit must revisit training, monitoring, and intervention protocols to prevent tragedies like Cedric Lofton’s and to avert civil liability. In the broader constitutional landscape, the ruling fortifies the national trend toward limiting high-risk restraints, especially on juveniles and individuals in mental-health crises, reaffirming that the Fourth Amendment’s protection “has no time limit.”