Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT DANA LITTLE v. CITY OF OWENSBORO, KENTUCKY; ART EALUM

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-29 The Sixth Circuit affirmed the district court’s grant of summary judgment in favor of the City of Owensboro, Police Chief Art Ealum, and Officer Wesley Dunn. The court held that Officer Dunn was entitled to qualified immunity on Dana Little’s federal excessive force claim under 42 U.S.C. § 1983 because he did not violate her clearly established Fourth Amendment rights. Applying the objective-reasonableness standard from *Graham v. Connor*, the court analyzed the severity of the crime, the threat posed by the suspect, and active resistance. While the court noted that the crimes involved were misdemeanors, it found that Little exhibited active verbal resistance to arrest. Regarding the safety threat, the court determined that even if Officer Dunn’s warrantless entry into the home to prevent Little’s son from retrieving a weapon was unconstitutional, the law was not clearly established at the time of the incident given the specific context of the 911 call alleging threats and violence, distinguishing the case from *Williams v. Maurer*. Consequently, the court also affirmed dismissal of Little’s state law claims for assault, battery, and malicious prosecution against Officer Dunn under Kentucky official immunity doctrines, finding no evidence of bad faith or malice. Finally, the court held that Little forfeited any independent liability claims against Chief Ealum and the City by failing to provide specific arguments supporting their separate liability in her brief. The judgment is affirmed, leaving the underlying state criminal charges pending. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.