The Tenth Circuit Court of Appeals recently ruled on the case of Lakey v. Bryant, affirming a lower court's decision regarding claims of excessive force and qualified immunity related to the death of Jared Lakey. The court's ruling affects the Lakey family, law enforcement practices in Oklahoma, and the broader discussion on police accountability.
Jared Lakey died after being restrained by police officers in Wilson, Oklahoma, in 2019. The incident involved multiple uses of a taser and a neck restraint applied by a deputy from the Carter County Sheriff's Office. Lakey's family, represented by co-Special Administrators Douglas and Cynthia Lakey, filed a lawsuit under 42 U.S.C. § 1983, alleging constitutional violations against Sheriff Chris Bryant and the officers involved. The case highlights critical issues surrounding police use of force and accountability.
The Lakey family claimed that Sheriff Bryant was liable for maintaining an informal custom of excessive force and for a Mutual Aid Policy that allegedly increased the risk of such force being used. The case reached the Tenth Circuit after the district court granted summary judgment for Sheriff Bryant, ruling that he was entitled to qualified immunity regarding the Mutual Aid Policy. The family appealed this decision, seeking to hold the sheriff accountable for the actions of his deputies.
During the incident on July 4, 2019, Jared Lakey was seen screaming naked in the street, prompting police intervention. Officers from the Wilson Police Department tased him fifty-three times within nine minutes, and Deputy David Duggan applied a chokehold restraint. Lakey later died, with the medical examiner attributing his death to a heart attack exacerbated by the use of tasers and the neck restraint. The Lakey family argued that Bryant's policies and lack of training contributed to the excessive force used against Lakey.
The Tenth Circuit's ruling, delivered by Judge McHugh, affirmed the lower court's decision, stating, "We see no basis for reversal." The court found that the Estate had not demonstrated that the Mutual Aid Policy violated clearly established law, thus upholding Bryant's qualified immunity. The court also noted that there was insufficient evidence to show a pattern of excessive force that would indicate an informal custom of such behavior.
Additionally, the court addressed the Lakey family's claims regarding the exclusion of evidence related to Deputy Duggan not being criminally charged for his actions. The court ruled that the district court did not err in excluding this evidence, stating that any potential error was harmless. The Tenth Circuit also upheld the denial of the Estate's motion for spoliation sanctions regarding Sheriff Bryant's destroyed text messages, concluding that the Estate failed to prove they were prejudiced by the loss of this evidence.
The ruling has significant implications for law enforcement practices, particularly regarding the use of force and accountability measures. It underscores the challenges families face in holding police departments accountable for actions that result in death or injury. The decision may also influence how police departments develop and implement training and policies to prevent excessive force incidents in the future.
Moving forward, the Lakey family has the option to appeal the ruling to the U.S. Supreme Court, although it remains unclear whether they will pursue this route. The case of Lakey v. Bryant serves as a critical reminder of the ongoing debate surrounding police practices and the necessity for transparency and accountability in law enforcement.