Headlocks & Handcuffs: When Use of Force Meets Qualified Immunity

Norman v. Ingle & Sutton, No. 24-20431 (5th Cir. Aug. 15, 2025)

Summary

Holding: The U.S. Fifth Circuit reversed the district court and found that Deputies Lee Ingle and Christopher Sutton did not violate Evan Norman’s clearly established constitutional rights. The court held that the Deputies were entitled to qualified immunity on all claims, including excessive force, failure to intervene, and denial of medical care.

Importance: This case underscores how crucial video evidence is in excessive force and qualified immunity cases. The court emphasized that where video contradicts a plaintiff’s version, summary judgment may be appropriate even when fact disputes exist. It also reaffirms the objective reasonableness standard from Graham v. Connor and stresses that individual officer actions must be assessed separately.

Limits: Officers still must act within constitutional bounds, and courts will closely analyze the reasonableness of use of force and any delay in medical care. But unless clearly established law puts officers on notice, qualified immunity remains a strong defense.

Facts

On March 21, 2021, Evan Norman went to Bombshells Restaurant & Bar in Texas and consumed at least seven alcoholic beverages in two hours. He fell asleep at the bar, prompting staff to call police. Deputies Ingle and Sutton arrived and asked Norman to go home or face arrest for public intoxication.

Norman became verbally antagonistic, asking for badge numbers and making mocking comments. The deputies gave him repeated verbal warnings to step back, which he ignored. Norman pointed a finger in Deputy Ingle’s face, and Deputy Sutton shoved him to create distance. Norman followed them again, and Ingle shoved him back, yelling “get the f--- back.” Norman swung at Ingle, missed, then placed Ingle in a headlock.

A brief struggle ensued:

• Sutton punched Norman.

• Ingle struck Norman multiple times—once while standing, then multiple times on the ground while kneeling on Norman’s arm.

• A third officer assisted in handcuffing Norman.

Norman was left face down for ~10 minutes awaiting EMS. He suffered significant facial injuries, including a broken nose and fractured orbital bones.

Norman sued the Deputies for excessive force, failure to intervene, denial of medical care, wrongful arrest, malicious prosecution, and First Amendment violations. The district court denied the Deputies’ motion for summary judgment on qualified immunity grounds. They appealed.

Issues

1. Were the Deputies entitled to qualified immunity for their use of force during the altercation?

2. Did Norman’s constitutional rights to medical care or officer intervention get violated?

3. Did Norman abandon other constitutional claims (false arrest, malicious prosecution, First Amendment)?

4. Could the Fifth Circuit resolve the appeal despite factual disputes, based on video evidence?

   
   

Court’s Decision (Holding)

The Fifth Circuit reversed the district court, holding that the Deputies were entitled to qualified immunity. The court found that:

• The force used was not objectively unreasonable under clearly established law.

• The delay in medical care did not rise to a constitutional violation.

• Deputy Sutton’s failure to intervene claim failed under the clearly established prong.

• Other claims were explicitly abandoned.

Reasoning

1. Jurisdiction Over Qualified Immunity Appeal

• Even with factual disputes, appellate courts can resolve qualified immunity appeals when video evidence provides “clarity.”

• The court has interlocutory jurisdiction to determine whether the facts state a violation of clearly established law.

2. Excessive Force

• The Graham factors controlled:

  1. Severity of crime: Minor (public intoxication).

  2. Threat: Norman swung at and grabbed a deputy.

  3. Resistance: Active, including a headlock.

• The force (strikes and punches) was responsive, proportional, and brief.

• No reasonable jury could find the force clearly unreasonable under the circumstances.

3. Denial or Delay of Medical Care

• Norman remained face down ~10 minutes post-arrest.

• However, Deputy Sutton immediately requested EMS.

• The court held this did not amount to deliberate indifference or a constitutional violation.

4. Failure to Intervene

• Norman claimed Sutton should have stopped Ingle’s punches.

• The court found:

  • The force lasted only seconds.

  • Sutton both encouraged and tried to end the force.

  • Norman did not cite any clearly established case requiring intervention in such a short time frame.

  • Sutton was thus entitled to qualified immunity.

5. Other Abandoned Claims

• In response to summary judgment, Norman conceded that he was no longer pursuing his:

  • False arrest

  • Malicious prosecution

  • First Amendment claims.

• The court deemed these abandoned and waived.

Street Takeaways (for Law Enforcement)

• Video footage is powerful: It can resolve factual disputes and secure immunity if it contradicts a plaintiff's version.

• Split-second decisions: Courts recognize the fast pace of real-world use of force events, especially when officers are attacked.

• Medical care: Immediate EMS requests are strong defenses—even if a suspect remains in an uncomfortable position temporarily.

• Failure to intervene claims must meet a high bar—officers need both time and awareness to act, and courts require clearly established law to deny immunity.

• Be careful with statements in reports or testimony—here, Norman’s lack of memory and abandonment of claims shaped the legal outcome.

• Individual officer conduct matters: Each deputy’s actions are evaluated on their own—not lumped together.

Disclaimer

This post is for training and informational purposes only. It is not legal advice. Officers should always consult their agency’s legal counsel or training division when making decisions based on court rulings.