ULYSSES LEE FEAGIN v. MANSFIELD POLICE DEPARTMENT; JORDAN MOORE; MARK BOGGS; CLAY BLAIR - Articles

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Posted by: Azya Thornton on Sep 11, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Melvin L. Lute, BAKER | DUBLIKAR, North Canton, Ohio, for Appellants.

Attorneys 2: ARGUED: Rachael Jensen, ORRICK, HERRINGTON & SUTCLIFFE LLP, Austin, Texas, for Appellee.

Attorneys 3: ON BRIEF: Melvin L. Lute, BAKER | DUBLIKAR, North Canton, Ohio, for Appellants.

Attorneys 4: ON BRIEF: Rachael Jensen, ORRICK, HERRINGTON & SUTCLIFFE LLP, Austin, Texas, Alyssa Barnard-Yanni, Daniel A. Rubens, ORRICK, HERRINGTON & SUTCLIFFE LLP, New York, New York, Samuel Weiss, RIGHTS BEHIND BARS, Washington, D.C., for Appellee.

Judge(s): CLAY, THAPAR, and READLER, Circuit Judges

Court Appealed: United States District Court for the Northern District of Ohio at Cleveland

READLER, Circuit Judge. Advancing technology reaches every corner of society. The law is no exception. Consider, on this front, the advent of portable recording devices, from those attached to the body (body cams) to those placed on a vehicle’s dashboard (dash cams). These innovations have dramatically changed our collective understanding of law enforcement encounters. Today, most officer interactions are captured on video. See Logan Seacrest & Jillian Snider, R St. Inst., The Past, Present, and Future of Police Body Cameras 3 (2025), https://perma.cc/2KKH-8LY3 (recognizing that over the past decade and a half police cameras have become “standard operating procedure” in the United States); see also Sean E. Goodison & Connor Brooks, Bureau Just. Stats., Local Police Departments, Procedures, Policies, and Technology, 2020–Statistical Tables 6 (2023), https://perma.cc/B8EC-TLQ4 (noting that as of 2020, 79% of local police officers worked in departments using body cams, with use ubiquitous in major urban areas). With those recordings typically available for broader viewing through public records laws and the like, body and dash cam video makes the work of law enforcement more open to public evaluation (and, invariably, debate). See, e.g., Ohio Rev. Code § 149.43(A)(1)(jj) (generally subjecting body cam and dash cam videos to public release). The court system has especially benefitted from these advancements. Whereas encounters with law enforcement historically had to be understood through witness recollections alone, video now captures key aspects of the engagement, if not the entire event itself. According to one recent study, video evidence has resulted in cases being “decided more quickly, with fewer disputed facts.” See Seacrest & Snider, supra at 3 (discussing how “body camera footage began to make its way from police stations to courtrooms”). For judges in particular, video evidence makes us far better equipped to evaluate claims tied to an officer’s conduct. Especially so in the interlocutory posture in which we review qualified immunity appeals, where we must measure that conduct against constitutional norms. In the past, it could be tempting to leave untouched a district court’s assessment of the evidence, as our review was limited to a paper record. See Johnson v. Jones, 515 U.S. 304, 307–09 (1995) (refusing to resolve factual dispute centered on dueling affidavits at summary judgment). But today, where video allows us in effect to witness the critical events at issue, we are equipped to assess for ourselves both the factual and legal questions underlying an officer encounter without reflexively deferring to the district court. After all, while we well appreciate the vital role district courts play in assessing live testimony or a complex record, we are on more equal footing in reviewing video evidence. See Johnson v. Rogers, 944 F.3d 966, 969 (7th Cir. 2019) (observing that a “conclusive video allows [an appellate] court to know what happened and decide the legal consequences”). Our jurisprudence over interlocutory qualified immunity appeals bears out these developments. In the increasingly rare excessive force case where the underlying record contains no video or audio record, and instead consists entirely of conflicting witness testimony, we have understood our role to be limited. Namely, it is for the jury, not us, to settle any underlying material factual disputes. Gambrel v. Knox County, 25 F.4th 391, 404–05 (6th Cir. 2022). But when presented with video footage that “accurately depicts most of the relevant events,” we may utilize that footage to “ensure [that] the district court properly constructed the factual record” and assessed the legal questions in line with that record. Heeter v. Bowers, 99 F.4th 900, 910 (6th Cir. 2024); Rudlaff v. Gillispie, 791 F.3d 638, 639 (6th Cir. 2015) (using video evidence when it captures the material facts); Hayden v. Green, 640 F.3d 150, 152 (6th Cir. 2011) (similar). Put another way, rather than “clos[ing] our eyes to the evidence presented” through dash or body cam, we instead “assess [that evidence] in the light depicted by the videotapes.” Moore v. Oakland County, 126 F.4th 1163, 1167 (6th Cir. 2025) (citation modified). This approach is now the rule more than the exception, with fewer and fewer police interactions occurring outside the scope of a camera’s lens. Today’s case is emblematic, with dash cam video vividly telling the tale of Ulysses Feagin’s most recent encounter with law enforcement officers. Now a prisoner, Feagin sued the officers under 42 U.S.C. § 1983, raising both excessive force and deliberate indifference claims tied to the officers’ deployment of a taser and pepper spray to effectuate Feagin’s arrest. The district court granted summary judgment to defendants on all but two claims: an excessive force claim related to the use of a taser, and a deliberate indifference claim stemming from the officers not tending to Feagin’s medical needs after he was pepper sprayed. Those remaining issues are now before us as part of the officers’ interlocutory appeal. As explained next, we reverse the district court’s denial of qualified immunity as to the excessive force claim, dismiss the appeal of the deliberate indifference claim for lack of jurisdiction, and remand to the district court for further proceedings.

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