Case Explained: JOSHUA PHILLIPS v. CITY OF HANCEVILLE ALABAMA KYLE DUNCAN JOSH HOWELL LOWELL ADAM HADDER

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-04 Docket: 5:22-cv-00987-LCB The eleventh-circuit affirmed the district court’s grant of summary judgment in favor of three police officers and the City of Hanceville on claims for false arrest, retaliatory arrest, and excessive force brought under 42 U.S.C. § 1983. The court held that the officers were entitled to qualified immunity because Phillips failed to establish a violation of clearly established constitutional rights. Specifically, the court ruled that the officers had probable cause to arrest Phillips for disorderly conduct and second-degree trespass under Alabama law, which defeated both the false arrest and retaliatory arrest claims, as an absence of probable cause is required to sustain a retaliatory arrest claim. Regarding excessive force, the court determined that the force used by Officers Duncan and Howell during the initial arrest was de minimis and reasonable given Phillips’s physical resistance, and that Deputy Chief Hadder’s use of force against Phillips while he was a pre-trial detainee was objectively reasonable under the Due Process Clause to maintain order. Consequently, because no underlying constitutional violation occurred, the City could not be held liable under *Monell*. The practical consequence is that the judgment for the defendants stands and the case is closed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.