Verbal Provocation Alone Cannot Render Otherwise Reasonable Force Excessive: Commentary on Medina v. City of Daytona Beach

I. Introduction

Anthony Medina v. City of Daytona Beach, No. 25-10552 (11th Cir. Nov. 21, 2025) (per curiam) is an unpublished Eleventh Circuit decision affirming summary judgment in favor of Daytona Beach police officers and the City on both federal and state claims arising from a post-arrest use of force.

The case sits at the intersection of several recurring issues in civil rights litigation:

How the Fourth Amendment “objective reasonableness” standard applies in a custodial, post-arrest setting;
How courts treat situations where the arrestee is verbally abusive, racially and homophobically insulting, and intermittently physically resistive;
The scope of qualified immunity for officers who use neck restraints and punches to control a handcuffed suspect;
The relationship between federal excessive-force standards and Florida tort claims for battery, assault, and negligence;
The limits of failure-to-intervene and municipal/vicarious liability when no underlying constitutional or tort violation is found.

Although designated “Not for Publication” and thus not binding precedent in the Eleventh Circuit, the opinion is a detailed application of existing law. It is especially notable for making explicit that:

Officer verbal provocation or unprofessional taunting—even including sexually suggestive and mocking responses to slurs—does not, by itself, convert otherwise reasonable physical force into a Fourth Amendment violation.
Brief neck restraints and short bursts of punches may be deemed objectively reasonable where a handcuffed arrestee is still non-compliant and actively struggling.
Florida battery claims for excessive force rise and fall with the federal excessive-force analysis.
Absent injury causally linked to alleged denial of medical care, negligence claims against the municipality fail as a matter of law.

II. Summary of the Opinion

Medina sued the City of Daytona Beach and several officers (Tucker, Pauth, Razmek, and Rolle) under 42 U.S.C. § 1983 for Fourth Amendment excessive force, and under Florida law for battery, vicarious liability, assault, and negligence. The district court granted summary judgment, holding that:

All officers were entitled to qualified immunity on the federal excessive-force claims;
The force used was objectively reasonable as a matter of law;
The state battery and vicarious liability claims failed because the force was not excessive;
The negligence claim failed because Medina had not alleged damages that stemmed from any failure to provide medical care.

On appeal, the Eleventh Circuit:

Reviewed summary judgment de novo, viewing the facts in the light most favorable to Medina except where video evidence contradicted his version (Brooks v. Miller standard);
Assumed the officers acted within their discretionary authority, thus placing the qualified immunity burden on Medina;
Applied the Graham v. Connor “objective reasonableness” framework and held that:
- Tucker’s neck holds and pushing Medina’s head down in the holding area were reasonable responses to Medina’s repeated failure to obey orders to sit and his continued verbal provocations;
- Tucker’s throat grab and push against the patrol car in the sally port were reasonable responses to Medina’s confrontational behavior and attempted kick to Tucker’s groin;
- The punches administered by Tucker and Pauth while Medina was on the ground, still struggling, for about sixteen seconds were reasonably proportionate to the need to subdue him;
- Rolle and Razmek could not be liable for failure to intervene where no underlying constitutional violation occurred;
- The City could not be liable because there was no violation by its officers.
Held that Medina’s state-law battery claims failed because Florida battery claims for excessive force are judged by the same reasonableness standard as federal excessive-force claims;
Held that the City could not be vicariously liable for assault or battery because, under Florida law, an employer’s liability is derivative of the employee’s—if the employee is not liable, neither is the employer;
Rejected the negligence claim for lack of causation: Medina did not allege injuries proximately caused by being left in the transport van without medical aid.

The Court thus affirmed summary judgment on all claims.

III. Analysis

A. Factual Background and the Role of Video Evidence

The factual narrative is critical because the Court’s application of qualified immunity and objective reasonableness is heavily fact-dependent. The panel explicitly applies the visual-evidence rule from Brooks v. Miller, 78 F.4th 1267 (11th Cir. 2023):

“Because this appeal comes to us on summary judgment, we view the facts in the light most favorable to Medina, unless video evidence ‘actually proves that [Medina’s] version of the facts cannot be true.’”

The sequence of events is broadly as follows:

Initial Stop and Arrest
- After midnight, an officer observed Medina’s car “swerving back and forth” and initiated a traffic stop for failure to maintain a single lane.
- Medina refused repeated requests to roll down the rear passenger window; backup was called.
- Medina exhibited classic signs of intoxication (glassy, bloodshot eyes; slurred, slow speech; odor of alcohol).
- He consented to field sobriety exercises but refused to complete them, and was arrested for DUI and agreed to a breath test at the station.
- He was handcuffed, placed in a patrol car, and “became increasingly belligerent” en route.
Holding Area and First Neck Restraint
- At the station, Officer Tucker (breath-test operator) escorted handcuffed Medina to a holding area and seated him.
- Video/audio showed Medina using racial and homophobic slurs; Tucker “taunting” Medina in return.
- Medina stood up; Tucker ordered him to sit, grabbed him by the neck, pushed him into the chair, and held his hands around Medina’s neck “for a few seconds.”
- The mutual taunting escalated; Medina made obscene references to Tucker’s mother; Tucker responded provocatively (“pull it out” and tongue gestures).
- After Medina again dared Tucker to touch him, Tucker tapped Medina’s knee with his foot. Medina stood again and refused repeated orders to sit.
- Tucker then grabbed the back of Medina’s neck, pushed his head down between Medina’s knees while other officers forced him into the chair. Tucker held his head there for “several seconds” (31 seconds for the entire sequence).
Refusal of Breath Test, Movement to Sally Port, and Throat Grab
- Medina refused the breath test; Tucker, Pauth, Rolle, and Razmek escorted him (still cuffed) to the sally port for jail transport.
- In the sally port, Medina confronted Tucker and called him “a pussy.”
- Tucker grabbed Medina by the throat, pushed him against the patrol car “several feet” away, and held his throat “for several seconds” until Pauth separated them.
- Officers re-cuffed Medina’s hands in front (from behind) while he was held against the vehicle.
- Seconds after being re-cuffed, Medina attempted to kick Tucker in the groin.
Ground Take-Down and Punches
- In response to the attempted kick, Tucker lunged at Medina and, along with Pauth and Rolle, took him to the ground.
- Tucker and Pauth punched Medina “multiple times” for about 16 seconds while Rolle attempted to control Medina’s legs.
- Rolle succeeded in controlling the legs; Tucker and Pauth then stopped punching “even before Razmek placed him in ankle cuffs.”
- Medina continued to verbally abuse officers and disobey commands.
Transport, Medical Evaluation, and Alleged Injuries
- Officers placed Medina in a transport van. At one point he appeared nonresponsive in the video.
- He was transported to the county jail, medically evaluated, and “cleared.”
- He suffered a cut on his forehead, bloody nose, allegedly deformed chin, PTSD, and believed he had been concussed and unconscious at some point.

The panel’s reliance on video evidence is central. By referencing exact durations (31 seconds and 16 seconds) and the timing of cessation of force, the court implicitly adopts the video as controlling on the degree and duration of force—an increasingly important pattern in modern civil rights litigation.

B. Federal Claims: Fourth Amendment Excessive Force and Qualified Immunity

1. Legal Framework: Qualified Immunity and Objective Reasonableness

The court notes that Medina did not dispute the officers were acting within their discretionary authority, so the burden shifted to him to overcome qualified immunity. Citing Jones v. Ceinski, 136 F.4th 1057 (11th Cir. 2025), the court recites the qualified immunity standard:

“[H]e ‘must establish that a reasonable jury could find that [the officers] violated [his] constitutional right . . . and that his right was clearly established when [the officers] violated it.’”

The panel chooses to resolve the appeal at the first prong—whether there was a constitutional violation—without reaching the “clearly established” prong. This is a common approach when the court believes the force was objectively reasonable, which avoids expanding the catalog of “clearly established” rights.

Substantively, the court applies Graham v. Connor, 490 U.S. 386 (1989):

All claims that law enforcement officers used excessive force in the course of an arrest, investigatory stop, or other “seizure” are analyzed under the Fourth Amendment’s “objective reasonableness” standard;
Courts must consider:
- The severity of the crime at issue;
- Whether the suspect poses an immediate threat to the safety of the officers or others;
- Whether he is actively resisting arrest or attempting to evade arrest by flight;
Courts must evaluate from the perspective of a reasonable officer on the scene, allowing for split-second decisions in tense, rapidly evolving situations.

The panel integrates the Eleventh Circuit’s gloss from Jones v. Ceinski:

“We consider ‘the relationship between the need and amount of force used and the extent of the injury inflicted.’”

2. The Court’s Treatment of Officer Intent and Verbal Taunts

A key feature of this opinion is its clear refusal to let officer taunting change the constitutional analysis. The court acknowledges Tucker’s “unprofessional” conduct:

“Because Officer Tucker’s intentions do not affect the objective reasonableness inquiry, that he may have provoked Medina throughout parts of the encounter, although unprofessional, is not dispositive.”

Citing Graham, the court reiterates:

“We do not consider an officer’s subjective intentions.”
“An officer’s evil intentions will not make a Fourth Amendment violation out of an objectively reasonable use of force; nor will an officer’s good intentions make an objectively unreasonable use of force constitutional.”

The panel cites Jones again to note that although an officer’s language can be considered in the “totality of the circumstances” analysis, “words alone [cannot] make . . . an otherwise proper[] use of force unconstitutional under the Fourth Amendment.”

This is one of the most significant doctrinal clarifications in the case: officer verbal provocation—even if coarse, mocking, or arguably incendiary—does not, standing alone, make force excessive if the level of force is otherwise proportionate to the suspect’s resistance and threat level.

3. Application to Specific Uses of Force

a. Holding Area: Neck Grabs and Pushing Medina’s Head Down

Medina argued that Tucker used excessive force in the holding area by:

Grabbing him by the neck and pushing him into the chair; and
Grabbing the back of his neck and forcing his head between his knees while other officers pushed him into the chair.

The Court’s analysis:

Medina was handcuffed but repeatedly refused commands to sit down.
The video showed an escalating pattern: verbal abuse, defiance of orders, and provocation.
The “entire encounter” from initial grab to release lasted about 31 seconds.

The panel emphasizes that because Medina failed to comply, “Tucker had the authority to use some degree of force to subdue him,” and concludes:

“[T]he force used here was ‘reasonably proportionate to the need for it.’”

Implicitly, the court weighs:

Severity of crime: DUI is a serious misdemeanor, but not a crime of violence.
Threat to safety: While handcuffed, Medina’s refusal to sit and continued escalation created a risk of loss of control in a custodial facility.
Resistance: Repeated, conscious defiance of direct orders.

On that record, the use of neck grabs and brief force to secure compliance is deemed reasonable. Importantly, the court does not treat neck contact as per se problematic, despite growing controversy around chokeholds and carotid restraints. Instead, it treats them as simply one more technique, to be judged under the Graham factors.

b. Sally Port: Throat Grab and Push Against Patrol Car

Medina also claimed that Tucker’s throat grab and “push” into the patrol vehicle constituted excessive force. The Court notes:

This occurred after Medina continued insulting Tucker and confronted him at the sally port;
Medina attempted to kick Tucker in the groin shortly after re-cuffing in front;
The entire sequence from lunge, throat grab, push, and taking Medina to the ground lasted only “a couple of seconds.”

Again, the court’s conclusion is that Tucker “had the authority to use some degree of force to subdue Medina,” and that this force was “reasonably proportionate” to the need to prevent further kicks and regain control.

The key doctrinal point: even when a suspect is handcuffed, an attempted kick at an officer’s groin is sufficient resistance and threat to justify physical measures including a throat grab, push into a vehicle, and takedown.

c. Ground Struggle: Punches by Tucker and Pauth

The most serious allegation involved punches delivered while Medina was on the ground. Medina contended that this was gratuitous and excessive, particularly as he was handcuffed (albeit re-cuffed in front).

The Court’s reasoning:

Medina continued to “struggle with the officers” on the ground;
Tucker and Pauth punched him for about 16 seconds while Rolle tried to immobilize his legs;
Once Rolle controlled Medina’s legs, Tucker and Pauth stopped punching “even before” ankle restraints were applied.

The panel quotes Graham on the need to account for “tense, uncertain, and rapidly evolving” circumstances and split-second judgments, then concludes that “like the other uses of force against Medina, this use of force was also ‘reasonably proportionate to the need for it.’”

This portion of the opinion underscores an important Eleventh Circuit principle already articulated in cases like Lee v. Ferraro and Fils v. City of Aventura:

“[A] police officer violates the Fourth Amendment, and is denied qualified immunity, if he or she uses gratuitous and excessive force against a suspect who is under control, not resisting, and obeying commands.” (quoting Jones, 136 F.4th at 1065)

Here, the panel effectively finds that Medina was not “under control, not resisting, and obeying commands” at the time of the punches. Because he remained actively struggling and had just attempted to kick an officer, the punches were framed as a legitimate part of the process of control, not post-control gratuitous violence.

4. Failure to Intervene: Officers Rolle and Razmek

Medina alleged that Officers Rolle and Razmek were liable for failing to intervene while Tucker and Pauth punched him. The panel cites Sebastian v. Ortiz, 918 F.3d 1301, 1312 (11th Cir. 2019):

“Plainly, an officer cannot be liable for failing to stop or intervene when there was no constitutional violation being committed.”

Because the Court held there was no excessive force, it follows a fortiori that the bystander officers could not be liable for failing to stop it. The court does not reach the separate question—often litigated—of whether Rolle and Razmek had a realistic opportunity to intervene, because the absence of a constitutional violation renders that inquiry irrelevant here.

5. Municipal Liability: The City of Daytona Beach

Medina argued that the City was liable for the officers’ actions. The opinion dispatches this in a single sentence:

“And because no constitutional violation occurred, a reasonable jury could not find that the City was liable for the actions of its officers.”

While the opinion does not analyze Monell doctrines explicitly, the logic is consistent with established law:

No underlying constitutional violation means there is nothing for a municipal policy or custom to “cause,” so municipal liability cannot attach.
The court avoids any discussion of whether the City maintained policies regarding neck restraints, training, or officer taunting, because that analysis would only be necessary if a constitutional violation were established.

C. State Law Claims

1. Florida Battery and Excessive Force

Medina alleged that Tucker, Pauth, Rolle, and Razmek committed battery under Florida law, and that the City was vicariously liable. The panel notes that Florida treats battery claims based on excessive force in a manner parallel to federal excessive-force doctrine, citing City of Miami v. Sanders, 672 So. 2d 46 (Fla. Dist. Ct. App. 1996):

“A battery claim for excessive force is analyzed by focusing upon whether the amount of force used was reasonable under the circumstances.”

Because the Court had already held that the officers’ use of force was not excessive under the Fourth Amendment, it simply applies the same reasoning to conclude that it was likewise reasonable under Florida law. Thus:

No battery by any officer; and
No vicarious liability for the City for battery.

2. Vicarious Liability and Assault for Knee Tap

Medina also argued the City was liable for assault based on Tucker’s act of touching Medina’s knee with his foot. The court does not find independent liability on this theory, in part because of Florida’s rule on derivative liability, citing Gabor v. Remington Lodging & Hosp., LLC, 413 So. 3d 261 (Fla. Dist. Ct. App. 2025), quoting Mallory v. O’Neil, 69 So. 2d 313 (Fla. 1954):

“‘[I]f the employee is not liable the employer is not liable.’”

Since the Court concluded there was no actionable battery or excessive force by Tucker, the City cannot be held vicariously liable for an alleged assault arising out of the same facts. The opinion also implicitly treats the knee tap as de minimis in the context of the overall interaction.

3. Negligence and Denial of Medical Care

Finally, Medina claimed the City was negligent in leaving him in the transport van without medical aid, particularly when he appeared nonresponsive. The Court relies on general negligence principles under Florida law, citing Fla. Dep’t of Corr. v. Abril, 969 So. 2d 201 (Fla. 2007):

“To maintain an action for negligence, a plaintiff must establish that the defendant owed a duty, that the defendant breached that duty, and that this breach caused the plaintiff damages.”

The panel’s conclusion is straightforward: whatever duty may have been owed, Medina failed to sufficiently plead or show that any of his alleged injuries were proximately caused by being left in the van without medical care. He was later evaluated and medically “cleared” at the jail. Thus, the negligence claim fails at the causation/damages element.

D. Precedents Cited and Their Influence

The opinion weaves together several key authorities. Each plays a discrete role in the analysis.

1. Brooks v. Miller, 78 F.4th 1267 (11th Cir. 2023)

Brooks provides the standard for how to treat video evidence at summary judgment:

Courts must view the facts in the light most favorable to the nonmovant, “unless video evidence actually proves that [the nonmovant’s] version of the facts cannot be true.”

In Medina, this principle:

Justifies the Court’s reliance on specific time durations (31 seconds, 16 seconds) and on observed conduct (e.g., Medina’s standing, refusal to sit, attempted kick);
Allows the panel to reject any characterization of the force as prolonged or gratuitous that is inconsistent with the video record.

2. Jones v. Ceinski, 136 F.4th 1057 (11th Cir. 2025)

Jones is cited for several core propositions:

The two-prong qualified immunity framework (constitutional violation and clearly established law);
The application of Graham’s factors and the need to weigh the “relationship between the need and amount of force used and the extent of the injury inflicted”;
The rule that officers violate the Fourth Amendment when they use “gratuitous and excessive force” against controlled, compliant suspects.

Medina arguably refines the Jones principle by clarifying that a suspect is not “under control” when he is actively resisting—even if handcuffed—and has just attempted to strike an officer.

3. Graham v. Connor, 490 U.S. 386 (1989)

Graham is the foundational excessive-force case, and Medina follows its script:

Focus on objective reasonableness, not subjective intent;
Use of the severity/ threat / resistance factors;
Recognition of officers’ need for split-second judgments in rapidly evolving situations.

The panel’s repeated quotations from Graham reinforce that it sees this case as an application, not an extension, of existing Fourth Amendment law.

4. Sebastian v. Ortiz, 918 F.3d 1301 (11th Cir. 2019)

Sebastian is invoked for the uncomplicated rule:

“[A]n officer cannot be liable for failing to stop or intervene when there was no constitutional violation being committed.”

This settles the failure-to-intervene claims against Rolle and Razmek without delving into timing or opportunity to intervene.

5. Florida Cases: Sanders, Gabor, Mallory, and Abril

City of Miami v. Sanders (1996):
- Aligns the standard for Florida battery claims with the federal excessive-force “reasonableness” standard.
- This alignment allows the court to “import” its Fourth Amendment analysis wholesale into the state-law battery analysis.
Gabor v. Remington Lodging & Hosp., LLC (2025) & Mallory v. O’Neil (1954):
- Establish that vicarious liability is derivative: if the employee is not liable, the employer is not liable.
- The panel uses this to dispose of the City’s vicarious liability for battery and assault once it finds the officers themselves non-liable.
Fla. Dep’t of Corr. v. Abril (2007):
- Articulates standard negligence elements: duty, breach, causation, and damages.
- The panel specifically emphasizes the causation/damages element, concluding that Medina alleged no injuries stemming from the alleged failure to provide medical care.

E. Complex Concepts Simplified

1. Objective Reasonableness

“Objective reasonableness” asks what a hypothetical reasonable officer would have done in the same situation, not what this particular officer intended or hoped to achieve. Factors include:

How serious the suspected crime is (e.g., DUI is serious but not inherently violent);
Whether the suspect appears dangerous (e.g., trying to kick an officer in the groin is dangerous);
Whether the suspect is actively resisting or trying to escape (e.g., ignoring commands, rising from seat, struggling on the ground).

The inquiry is performed with some deference to the fact that officers often must make fast decisions in stressful, uncertain conditions.

2. Qualified Immunity

Qualified immunity is a legal doctrine that shields government officials from civil damages unless:

They violated a constitutional right; and
The right was “clearly established” at the time in such a way that a reasonable officer would have understood the conduct to be unlawful.

In Medina, the court never reaches step (2) because it concludes there was no constitutional violation at step (1).

3. “Gratuitous” Force vs. Control-Based Force

Courts distinguish:

Force used to gain control over a resisting suspect (often permissible if proportionate); and
“Gratuitous” force used after a suspect is fully subdued, not resisting, and compliant (often unconstitutional).

In Medina, the court treats all contested force as part of the process of imposing control: Medina is never portrayed as fully subdued and compliant at the time force is used.

4. Failure to Intervene

Officers have a duty to intervene if:

They are aware that a fellow officer is using excessive force; and
They have a realistic opportunity to stop it.

However, if no excessive force occurs, then officers cannot be liable for failing to intervene, as there is nothing unlawful to prevent. That is the logic applied to Officers Rolle and Razmek.

5. Vicarious Liability and Derivative Nature of Employer Liability

In both federal and Florida law, claims that an employer is responsible for the acts of an employee usually require:

An underlying tort or constitutional wrong by the employee; and
A legal theory (respondeat superior, policy or custom, etc.) connecting the employer to that wrong.

If the employee did nothing actionable, the employer ordinarily cannot be held vicariously liable for that same conduct. Medina follows this rule.

6. Proximate Cause in Negligence

To prove negligence, it is not enough to show the defendant did something wrong; the plaintiff must show:

The wrongful act (breach of duty) actually caused the injury; and
The injury was a reasonably foreseeable result of that breach.

In Medina, even if leaving him in the van was arguably negligent, he did not show that any of his complained-of injuries (cuts, nose bleed, PTSD, possible concussion) were caused by that fact, as opposed to the earlier physical altercation. Therefore, the negligence claim fails.

F. Impact and Future Implications

1. Status as Unpublished, But Persuasive, Authority

The opinion is labeled “NOT FOR PUBLICATION,” which in the Eleventh Circuit generally means it is not binding precedent. However, it still:

Signals how the current Eleventh Circuit views similar fact patterns;
May be cited as persuasive authority (where local rules permit) to support or distinguish other excessive-force cases;
Reflects the court’s application of Graham, Jones, and Brooks to bodily force, neck restraints, and brief punching episodes.

2. Treatment of Verbal Provocation by Officers

One of the most important practical takeaways is that officer taunting, crude comments, or unprofessional language will rarely, if ever, transform otherwise reasonable force into a constitutional violation.

For plaintiffs, this underscores that:

Evidence of racial or homophobic slurs, while potentially powerful before a jury, is not dispositive on the Fourth Amendment question;
Courts will focus primarily on physical conduct and resistance, not words, in applying the reasonableness test.

For law enforcement agencies:

Agencies may still discipline officers for such language or provocation as a matter of internal policy and professionalism;
But the constitutional analysis will remain focused on physical force, not verbal conduct.

3. Neck Restraints and Punches in the Post-Arrest Setting

Medina will likely be cited in future cases involving:

Brief neck grabs or holds used to force seated compliance or prevent kicks;
Short bursts of punches deployed while a handcuffed suspect is struggling on the ground.

The opinion suggests that:

Courts will tolerate short-duration, targeted strikes in response to active resistance, especially where the suspect is attempting to kick or otherwise assault officers;
Officers should terminate such force once control is achieved; here, stopping after 16 seconds and after leg control is attained is a key fact supporting reasonableness;
Duration and context (e.g., ongoing resistance vs. post-restraint) will be critical in future excessive-force analysis.

4. Video Evidence as the Central Arbiter

Like many modern excessive-force decisions, Medina shows that video footage is decisive:

Exact timing of events (seconds) and precise sequences (stand up, refusal, grab, release) are taken directly from the video;
Any plaintiff narrative that conflicts with clear video evidence will be disregarded at summary judgment.

Practitioners must, therefore:

Scrutinize video closely to identify any ambiguity, gaps, or angles favorable to their client;
Recognize that clear video evidence can override self-serving affidavits or depositions that contradict the visual record.

5. State Law Claims Track Federal Outcomes

The opinion reinforces a trend in Florida and Eleventh Circuit practice:

Florida battery claims based on excessive force will typically succeed or fail with the federal Fourth Amendment claim.
Vicarious liability is strictly derivative; without underlying liability of the officer, the city or employer will usually be out as well.
Negligence claims premised on denial of care require careful pleading of specific injuries caused by the alleged delay or denial; generalized injury from the underlying altercation is insufficient.

Strategically, plaintiffs may need separate, well-developed factual theories for negligence claims (e.g., exacerbation of injuries due to delay in treatment), backed by medical evidence tying the additional harm specifically to the denial of care.

IV. Conclusion

Medina v. City of Daytona Beach is a robust application of longstanding Fourth Amendment and Florida state-law principles to a fact pattern involving: a drunk driving arrest, unrestrained verbal abuse, intermittent physical resistance, and the use of neck restraints and punches by officers.

The key takeaways are:

Verbal provocation—whether by the suspect or the officer—does not, by itself, make force excessive under the Fourth Amendment.
Brief, targeted force (including neck grabs and punches) can be constitutionally reasonable when used to control a non-compliant, struggling, and partially restrained arrestee, especially after an attempted assault on an officer.
Failure-to-intervene and municipal liability claims collapse if no underlying constitutional violation is established.
Florida battery and assault claims based on excessive force are evaluated under the same reasonableness standard as federal excessive-force claims.
Negligence claims premised on denial of care require clear proof that specific injuries were caused by that denial, not by the prior use of force.

While not precedential, Medina illustrates how the Eleventh Circuit is likely to view similar cases going forward: through a lens that gives substantial weight to video evidence, emphasizes active resistance and immediate threat over verbal conduct, and demands tight causal connections between alleged official misconduct and claimed injuries.