Harry Coles v. Joshua Eagle

Plaintiff Harry J. Coles claims that defendants Joshua Eagle and Elton Robertson, officers of the Honolulu Police Department, used excessive force in arresting him. The officers moved for summary judgment, arguing that their conduct was reasonable and, in any event, that they were entitled to qualified immunity. Although Coles brought a single claim of excessive force under 42 U.S.C. § 1983 , the district court held on summary judgment that some of the officers’ actions were reasonable as a matter of law, but other parts of the encounter raised genuine issues of material fact. See Coles v. Eagle, 753 F.Supp.2d 1092 (D.Hawai’i 2010). A jury was then asked to assess the reasonableness of only some aspects of the officers’ conduct; it found in their favor. Coles argues that the district court improperly resolved factual disputes and made inferences in favor of the officers, and that the subsequent jury verdict must be vacated because the jury was erroneously instructed that some of the officers’ force was reasonable as a matter of law. We agree.

I.

A. The Arrest

The following events happened over the course of approximately four minutes, in the middle of the night. Coles…