Michael Seals v. Rodney Mitchell

MEMORANDUM

Michael Izell Seals claims that Lake County, California, Sheriffs Department Officers John Rynhart and Lyle Thomas used excessive force during Seals’ arrest for cocaine possession. The officers maintain that they used reasonable force to prevent Seals from swallowing a bag of cocaine. The arrest led to Seals’ conviction, affirmed on appeal, for possession and transportation of cocaine base. People v. Seals, 2006 WL 1613986 , at *1 (Cal. Ct.App.2006).

Seals brought action under 42 U.S.C. § 1983 , claiming that his right shoulder sustained injury during the arrest. The officers’ medical expert, an orthopaedic surgeon, reviewed Seals’ medical records and testified that Seals suffered a congenital shoulder abnormality, documented in medical records predating his arrest, that made him vulnerable to the condition he suffered: an “impingement” of the shoulder. Accordingly, the physician opined that Seals’ shoulder pain was not caused by the arrest. Following a three-day trial during which Seals was represented by appointed counsel, the jury returned a ver-diet in favor of the officers. Seals’ motion for a new trial was denied.

Seals now appeals. We have jurisdiction under…