The US Court of Appeals for the Fourth Circuit recently issued a ruling that partially favored Caron Nazario, a Black and Latino Army lieutenant who claimed he experienced excessive force during a traffic stop. The court delivered a partial judgment on Friday, reversing a lower court’s decision to grant qualified immunity to police officer Joe Gutierrez against Nazario’s Fourth Amendment claim for an unreasonable seizure.
In a controversial 2020 traffic stop, Nazario was pepper-sprayed, handcuffed, and threatened by two Virginia police officers. The officers stopped him under the pretense that his vehicle lacked a rear license plate, despite the fact that it had a temporary tag. The incident was recorded, and the video showcased the officers pointing handguns at Nazario. The Fourth Circuit majority highlighted that Nazario’s refusal to exit the vehicle was considered non-compliant, which was a pivotal factor in the initial decision made by the trial court.
The Fourth Amendment protects against unreasonable searches and seizures. U.S. Circuit Judge Robert King noted that, “It can be unconstitutional to hold a person at prolonged gunpoint when he is compliant and presents no danger to the public or law enforcement officers.” The appellate court’s ruling emphasized that the principle of reasonableness under the Fourth Amendment can be violated by using unwarranted deadly force when compliance is evident.
Although the lower court had dismissed Nazario’s excessive force and unreasonable seizure claims based on the officers’ probable cause due to his non-compliance, the appellate court disagreed with granting qualified immunity to Officer Gutierrez. The appeals court’s decision aligns with broader concerns over police conduct towards Black individuals during traffic stops, echoing public sentiment on the issue.
Notably, a jury awarded Nazario $2,685 in compensatory damages last year, acknowledging the emotional and physical distress caused by the encounter. While the appellate court’s decision does not fully vindicate Nazario, it denotes a significant step towards addressing grievances relating to excessive force claims.
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