Case Explained: Non-Argument Calendar TYLER LEE CANARIS v. MICHAEL MCMASTER

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-23 Docket: 4:23-cv-00215-WMR The Eleventh Circuit affirmed the district court’s grant of summary judgment in favor of Deputy Michael McMaster and Sheriff Gary Gulledge, dismissing Tyler Canaris’s claims for excessive force under the Fourth Amendment and state law torts. The court applied the qualified immunity standard, determining that Deputy McMaster’s actions were objectively reasonable under the circumstances outlined in *Graham v. Connor*. Specifically, the panel found it reasonable for the officer to believe Canaris might be reaching for a weapon given his resistance and sudden arm movements while being detained for suspected car break-ins, thereby justifying the use of force to restrain him. The court further held that Canaris failed to provide evidence of actual malice or intent to injure required to overcome Georgia’s official immunity doctrine for state law claims. Regarding Sheriff Gulledge, the court ruled that supervisory liability cannot be established under *respondeat superior* and requires a direct causal connection to an underlying constitutional violation; since no Fourth Amendment violation occurred, the claim against the Sheriff in his individual capacity was properly dismissed. The practical consequence is that the judgment for the defendants stands, and Canaris’s lawsuit is terminated without relief. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.