“Active-Resistance Reasonableness” – Seventh Circuit Re-affirms Split-Second Force and Prompt Post-Restraint Care in Snukis v. Taylor

1. Introduction

On 28 July 2025 the United States Court of Appeals for the Seventh Circuit delivered a significant Fourth Amendment decision in Edward C. Snukis, Jr. & Samantha Snukis v. Matthew O. Taylor. The court addressed whether two taser deployments, six closed-fist head strikes, and a post-handcuff medical response violated the constitutional rights of an intoxicated and combative suspect who later died. Plaintiffs—children of the decedent and co-administrators of his estate—sued three Evansville police officers under 42 U.S.C. §1983 for excessive force, failure to intervene, and failure to render medical aid. The district court entered summary judgment for the officers; the Seventh Circuit, in an opinion by Judge Kirsch, affirmed.

2. Summary of the Judgment

Excessive force: All three discrete uses of force—Koontz’s arm grab, Taylor’s twin taser shots, and Taylor’s six head strikes—were objectively reasonable under Graham v. Connor.
Failure to intervene: Because no underlying excessive force was established, the derivative claim failed.
Medical-care claim: Officers responded promptly and adequately once they noticed Snukis’s loss of consciousness; their conduct satisfied the Fourth Amendment’s reasonableness standard.
Procedural holdings: The estate forfeited factual disputes and legal theories not properly raised at summary-judgment stage (Packer v. Trustees of Indiana Univ.).
Outcome: Judgment of the district court affirmed in full.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

Graham v. Connor, 490 U.S. 386 (1989) – The touchstone “objective reasonableness” test supplied the analytical frame: severity of crime, immediate threat, active resistance.
Torres v. Madrid, 592 U.S. 306 (2021) – Reiterated that any physical force with intent to restrain is a seizure, situating taser use within Fourth Amendment scrutiny.
Abbott v. Sangamon County, 705 F.3d 706 (7th Cir. 2013) & Dockery v. Blackburn, 911 F.3d 458 (7th Cir. 2018) – Positioned tasers “mid-spectrum” and allowed them against active resistors; these cases undergirded the finding that Taylor’s taser deployments were proper.
Cyrus v. Town of Mukwonago, 624 F.3d 856 (7th Cir. 2010) – Illustrated excessive taser use on a subdued suspect; contrasted against Snukis’s continuous struggle.
Brumitt v. Smith, 102 F.4th 444 (7th Cir. 2024); Sallenger v. Springfield, 630 F.3d 499 (7th Cir. 2010) – Emphasised officers need not calibrate force “at the precise second” threats evolve, endorsing Taylor’s rapid six-strike sequence.
Horton v. Pobjecky, 883 F.3d 941 (7th Cir. 2018); Florek v. Mundelein, 649 F.3d 594 (7th Cir. 2011) – Articulated the four-factor medical-aid test; court analogised officers’ prompt CPR to those decisions.
Packer v. Trustees of Indiana Univ., 800 F.3d 843 (7th Cir. 2015) – Provided the forfeiture rule that barred new factual theories on appeal.
Bradich v. City of Chicago, 413 F.3d 688 (7th Cir. 2005) – Distinction: there the 10-minute delay was deliberate indifference; here, officers reacted within seconds.

3.2 Court’s Legal Reasoning

Tactical Escalation Assessment
Judge Kirsch parsed each force application in chronological order, aligning it with the Graham factors: suspected trespass + intoxication indicated a modest crime, but Snukis’s strike on Koontz and attempt to disarm/grab Taylor elevated the threat. The taser—classified as intermediate force—was warranted by active flight and hands-on resistance. The head strikes were judged proportionate because prior pain-compliance measures (taser x2, joint manipulation) had failed.
“Split-Second” Temporal Lens
The panel reemphasised that reasonableness is examined from the on-scene perspective, not hindsight. Officers are not required to “pause” between blows or switch tactics the moment resistance marginally changes (Brumitt).
Evidence Control & Forfeiture
The estate’s attempts to dispute video-supported facts (whether Snukis struck Koontz or grabbed at Taylor) were rejected because those disputes were not raised at summary judgment and lacked record citations. The opinion is a cautionary tale on Rule 56 precision.
Medical-Aid Framework
Applying the four-factor test, the panel held that officers (a) noticed distress almost immediately, (b) confronted a serious need, (c) provided sternum rubs, airway checks, handcuff removal, and CPR, and (d) balanced care with officer-safety concerns. The constitution demands “reasonable,” not instantaneous, medical help; the seconds-long delay while securing an actively resistant suspect was permissible.

3.3 Likely Impact of the Decision

Codifying “Active-Resistance Reasonableness” – The case solidifies Seventh Circuit precedent that intermediate force (tasers, focused head strikes) remains reasonable so long as resistance continues, even after initial pain-compliance fails.
Body-Camera Primacy – The court again treats clear video as near-conclusive, limiting litigants’ ability to manufacture factual disputes.
Procedural Discipline – Litigants must articulate each discrete use-of-force theory at the Rule 56 stage; omissions are forfeited on appeal.
Medical-Aid Timing – The opinion will be cited to defend officers who delay aid only long enough to ensure scene safety; Bradich remains the outlier requiring more stringent care in non-combative contexts.
Training & Policy – Agencies may rely on the decision to justify continued taser deployment protocols and instruct officers on immediate post-restraint monitoring and CPR.

4. Complex Concepts Simplified

Objective Reasonableness: A standard asking: “Would an ordinary, prudent officer in the same circumstances think this amount of force is necessary?” It ignores the officer’s subjective intent.
Taser (Conducted Energy Device): A non-lethal weapon that delivers an electric charge to cause neuromuscular incapacitation, considered “intermediate” force—more than handcuffs, less than lethal weapons.
Sternum Rub: A painful stimulus (knuckle rub to chest bone) used by first responders to test responsiveness.
Forfeiture vs. Waiver: Forfeiture is the loss of a claim through failure to raise it timely; waiver is the intentional relinquishment of a known right. Here, plaintiffs forfeited certain arguments by silence at summary judgment.
Summary Judgment (Rule 56): A procedural device allowing a court to dispose of claims that present no genuine dispute of material fact, saving trial for contested matters.

5. Conclusion

Snukis v. Taylor refines the Seventh Circuit’s Fourth Amendment jurisprudence in two interconnected domains: the permissible continuum of force against an actively resisting suspect, and the constitutionally sufficient speed of post-restraint medical intervention. The court’s methodical segmentation of each force application—and its insistence on record-based factual disputes—supplies a blueprint for officers, litigators, and trial judges. Practically, the decision encourages:

Clear, contemporaneous body-camera activation;
Graduated but firm use of intermediate force when resistance persists;
Immediate vital-sign monitoring after handcuffing, followed by CPR if needed;
Meticulous summary-judgment briefing that targets each discrete act of force.

In the broader landscape, the precedent fortifies the principle that the Fourth Amendment does not nit-pick officers’ split-second tactics when confronted with aggression, yet holds them to a prompt, measured duty of care once control is achieved. Future plaintiffs will need concrete, contemporaneously asserted facts distinguishing their cases from the “active-resistance reasonableness” validated here.