Parish
- Lafayette City Parish
Police Department:
- Lafayette Police Department
Summary:
The American Civil Liberties Union of Louisiana and Freshfields US LLP filed an appeal in the United States Court of Appeals for the Fifth Circuit on behalf of Mr. Raynaldo Markeith Sampy Jr. Mr. Sampy is a Black male who was sleeping in his car when he was arrested and subjected to excessive force by members of the Lafayette Police Department.
Mr. Sampy filed suit against the officers involved, as well as the Lafayette City Parish Consolidated Government, for violations of his constitutional rights. Mr. Sampy asserted that officers used excessive force against him while he was handcuffed—including, but not limited to, when an officer employed a maneuver, referred to as “snapping the sheet” (i.e., snapping someone’s body like a bedsheet), at the scene. At the time, Mr. Sampy was handcuffed, with his face pressed against a police vehicle, while his legs were held in midair. In that position, he was yanked by his legs backward, so that he fell face-first onto the concrete pavement. He cut his chin, which immediately started to bleed; he was then knelt on by that officer and another as he lay in a pool of his own blood. The other officers on the scene did not intervene or otherwise attempt to halt this excessive force, which Mr. Sampy claims was retaliation for exercising his right to tell the officers that their actions violated his rights.
Mr. Sampy was convicted in Louisiana State Court of simple battery of a police officer for kicking an officer in the shin after he was handcuffed, when his face was pressed against the police vehicle, but before his legs were subsequently held in midair in response to the kick.
The district court granted Defendants’ motion to dismiss a number of Mr. Sampy’s excessive force claims, finding them barred by the Heck doctrine. Heck bars civil claims that, if successful, would necessarily undermine a criminal conviction. Heck does not bar claims if they are temporally and conceptually distinct from the conviction. The district court found that some of Mr. Sampy’s claims were not temporally distinct from his conviction because they occurred before he “ceased resisting.” The district court also found that Mr. Sampy’s kick occurred “simultaneously” with officers snapping Mr. Sampy like a sheet.
On appeal, Mr. Sampy argues that the district court improperly dismissed two of his excessive force claims under Heck—when he was snapped like a sheet, and when he was subsequently knelt on. He argues that these claims are temporally distinct from his conviction, and thus not Heck-barred, because the excessive force occurred after the battery. He explains that the district court erred by looking at whether force was used after his “resistance ceased,” rather than after the act for which he was convicted: battery. Mr. Sampy also argues the district court misinterpreted a statement from the criminal court to find that his kick occurred “simultaneously” with officers yanking him off the hood of the police vehicle, and that the record does not support such a finding when construed in his favor. In sum, Mr. Sampy explains that two of his excessive force claims are not Heck-barred because it can both be true that he kicked the officer and that the officers used excessive force in response. He asks the appellate court to reverse the trial court’s Heck ruling such that he is entitled to a trial on two excessive force claims that the jury in his case was never allowed to consider.
Defendant-Appellees in this case are:
- Jordan Kamal Colla
- Brandon Lamar Dugas
- Segus Ramon Jolivette
- Ian James Journet
- Lafayette Consolidated Government
- Jonathan Price Rabb
- Asher Reaux