Qualified immunity denied when subject dies of heart attack while being violently seized


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On March 9, 2021, Caddo Parish Sheriff’s Office Deputy Ryan Chapman and other deputies attempted to execute an arrest warrant for Chad Deloach. The deputies believed that Deloach was living on William E. Walls’s Keithville property. When the deputies arrived at the property, Walls told them he did not know Deloach’s location and cooperated with their investigation. Walls invited the deputies into his home so they could search for Deloach. Walls also offered to call his son, who lived in a separate trailer on his property, and ask him where Deloach was. Deputy Chapman rejected Walls’s offer, cursed at him, threatened him, and ordered him back inside his home. Walls obeyed but revoked consent for the deputies to re-enter his home.

Upon returning inside his home, Walls observed the deputies searching the exterior of another residence on his property. As Walls watched the deputies through the windows of his home, he held his phone. Chapman saw Walls with his phone and thought that he was videotaping the deputies. In response, Chapman forced his way into Walls’s home. Chapman forcefully grabbed Walls, threw him against his kitchen counter, handcuffed him, aggressively and violently pulled him from his home, slammed him against the hood of the patrol car, and forced him into the back of the car.

After a short period of time detained in the patrol car, Walls (a senior citizen) suffered a heart attack and stopped breathing. The deputies pulled him from the patrol car and administered CPR. Walls died at the scene. Walls’s two surviving sons filed a lawsuit against Chapman, asserting excessive force claims pursuant to 42 U.S.C. § 1983.

Chapman invoked qualified immunity as a defense to the § 1983 excessive force claim. The district court denied Chapman’s qualified immunity defense. The 5th affirmed the district court.


To win, plaintiffs must overcome qualified immunity. That means they must show (1) that Chapman violated Walls’s constitutional rights and (2) that the right at issue was “clearly established” at the time of the alleged misconduct. See Salazar.

Deputy Chapman challenges only the second requirement—clearly established law. So that is all we address. Qualified immunity protects all but the plainly incompetent or those who knowingly violate the law. See SCOTUS District of Columbia v. Wesby, 583 U.S. 48, (2018). It shields officers from civil liability so long as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known. See SCOTUS City of Tahlequah v. Bond, 595 U.S. 9 (2021).

To show a violation of clearly established law, the plaintiff must identify a case that put the officer on notice that his specific conduct was unlawful. Courts must be careful not to define clearly established law at too high a level of generality. In particular, excessive force is an area of the law in which the result depends very much on the facts of each case, and thus police officers are entitled to qualified immunity unless existing precedent squarely governs the specific facts at issue. See SCOTUS Kisela v. Hughes, 138 S. Ct. 1148 (2018).

Two of our cases are relevant here. In Bush, we denied qualified immunity where the officer slammed a compliant arrestee’s face into the window of a nearby car, injuring her jaw and teeth. And in Deville, we denied qualified immunity where the officer pulled over a woman for speeding, ordered her out of the car, and then (when she did not comply) broke the vehicle’s window, pulled the woman out, and caused her multiple injuries (including contusions to both wrists, neuropathy of her hands, right shoulder strain, left shoulder bruising (with hand prints), and multiple cuts caused by broken glass).

Under Bush and Deville, the district court did not err. On the well-pleaded facts of this case, Walls was not suspected of any crime, posed no immediate threat to the safety of the deputies or others, and made no attempt to actively resist arrest or evade arrest by flight. Chapman violently seized Walls only because Chapman mistakenly thought Walls was videotaping the officers. There was no evidence that Chapman’s actions were compelled by necessity and exigency. Walls was injured in the arrest and then died.

Assuming the truth of the facts as pleaded, Chapman violated clearly established law. AFFIRMED.