Johnson v. County of Los Angeles

In the course of his flight from police and ensuing arrest for armed robbery, James Johnson (“Johnson”) was rendered a paraplegic. He brought claims arising from his injury against several of the involved law enforcement officers, medical service workers, and their employer, the County of Los Angeles. Relevant to this interlocutory appeal is a 42 U.S.C. § 1983 claim against Deputy Michael Woodard (“Deputy Woodard”) for excessive use of force, which Johnson asserts was the direct cause of his paraplegia. Deputy Woodard challenges the district court’s denial of his motion for summary judgment seeking qualified immunity. We reverse and remand with instructions to enter summary judgment in favor of Deputy Woodard.

BACKGROUND

In September 1999, Johnson, on parole from prison, and Myron Edwards (“Edwards”) robbed a bank in Malibu, California. The record is clear that law enforcement authorities were immediately informed that it was an armed robbery. The robbers fled from the bank in a red Chevrolet Corsica, with Edwards driving and Johnson lying down in the back seat. Johnson was not wearing a seatbelt. When Los Angeles County Sheriffs deputies spotted the suspect vehicle,…