Case Explained: LEGACY SPENCER, as the Administrator for the Estate of Sylvester Demetrius Selby Plaintiff – v. EDWARD GLASER, III

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-04 The fourth circuit affirmed the district court’s dismissal of a civil rights complaint alleging that a deputy used excessive force in violation of the Fourth Amendment and state law after shooting a suspect who was holding a knife. Applying de novo review, the court held that the district court properly considered body camera footage because it blatantly contradicted key factual allegations in the complaint regarding the suspect’s movements and intent. Under the objective reasonableness standard of *Graham v. Connor*, the court determined that the deputy had probable cause to believe the suspect posed an imminent threat of serious physical harm, as the suspect defied commands to drop a weapon, charged toward officers, and lunged at an officer even after being initially shot. Consequently, the use of deadly force was objectively reasonable, precluding a plausible Fourth Amendment claim. The court also affirmed the dismissal of state-law assault, battery, and wrongful death claims, noting that the deputy was entitled to public official immunity because he did not act with malice, and the sheriff could not be held liable under *respondeat superior* for actions that were lawful. The practical consequence is that the complaint remains dismissed, and no further litigation on these merits is permitted. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.