Spencer v. Benison

On July 7, 2017, Huntsville, Alabama police officer William Benison responded to a call about a man with a gun. He encountered Gregory Spencer holding a BB gun that resembled a firearm. Benison ordered Spencer to drop the weapon and then fatally shot him. Spencer’s mother, Bridget Spencer, as administratrix of his estate, filed a federal civil rights lawsuit under § 1983, alleging excessive force in violation of the Fourth Amendment. The district court granted summary judgment to Benison on qualified immunity grounds, finding that the use of deadly force was reasonable. The plaintiffs appealed, arguing that material factual disputes existed about whether Spencer posed an immediate threat. The Eleventh Circuit reversed, holding that a reasonable jury could find that Spencer did not point the gun at officers and that the shooting was objectively unreasonable, thereby stripping away qualified immunity.

The United States Court of Appeals for the Eleventh Circuit reversed the district court's grant of summary judgment, holding that disputed material facts precluded qualified immunity, and remanded the case for further proceedings.

Whether Officer Benison’s use of deadly force was objectively unreasonable under the Fourth Amendment, and whether he was entitled to qualified immunity when factual disputes remained as to whether Spencer pointed the BB gun at him before being shot.

The case drew renewed attention to the qualified immunity doctrine and its role in shielding police officers from accountability in fatal shootings. Civil rights advocates cited Spencer v. Benison as an example of appellate courts recognizing that juries, not judges, should resolve key factual disputes in excessive force cases. It also contributed to ongoing legislative and public debates about reforming qualified immunity and strengthening police use-of-force standards across the United States.