Case Explained: Tamala J. Jones, Personally, and as the Administratrix of the Estate of Tramon Tyqueze Savage v. Logan K. Kulesa; Shawn M. Jones

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-06-18 The eighth-circuit dismissed the interlocutory appeal filed by police officers Logan Kulesa and Shawn M. Jones challenging the district court’s denial of their motion for summary judgment based on qualified immunity in a 42 U.S.C. § 1983 excessive force action. The court held that it lacked jurisdiction to review the denial because the officers’ arguments centered on material factual disputes rather than purely legal questions. Under Eighth Circuit precedent, appellate jurisdiction over qualified immunity denials is limited to determining whether the conduct violated clearly established federal law based on facts adequately supported in the record; the court cannot resolve genuine disputes of fact or determine which party may prove specific facts at trial. The officers argued that video evidence conclusively showed they faced an immediate threat, but the court found the videos did not “blatantly contradict” the district court’s finding that it was disputed whether Savage posed a serious and immediate threat after his vehicle struck a wall and stopped. Because resolving the officers’ claim required the appellate court to cast aside the district court’s factual findings and resolve genuine factual disputes, the appeal was dismissed for lack of jurisdiction. The practical consequence is that the denial of qualified immunity stands, allowing the excessive force claim to proceed to trial in the district court where a jury will resolve the disputed facts regarding the reasonableness of the officers’ use of force. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.