Malone et al v. City of Decatur, Alabama et al

On October 9, 2018, in Decatur, Alabama, police officers responded to a mental health crisis call involving Rodney Malone. During the encounter, officers deployed a Taser and ultimately shot Malone, resulting in his death. The plaintiffs, including Malone's estate and his mother Janet Malone, filed a federal civil rights lawsuit against the City of Decatur, its police department, and Officer Michael Green. They alleged excessive force in violation of the Fourth Amendment, as well as state law wrongful death claims. The defendants moved for summary judgment, raising the defense of qualified immunity. The district court granted summary judgment for the officers, and the plaintiffs appealed. The U.S. Court of Appeals for the Eleventh Circuit affirmed, holding that the officer did not violate clearly established law at the time of the incident. The case underscored the high bar plaintiffs face in overcoming qualified immunity in police shooting cases.

The U.S. District Court for the Northern District of Alabama granted summary judgment in favor of the defendants on the basis of qualified immunity. The Eleventh Circuit affirmed, ruling that the officer did not violate clearly established statutory or constitutional rights.

Whether the officer's use of deadly force against a mentally ill individual constituted excessive force under the Fourth Amendment, and whether the officer was entitled to qualified immunity given the circumstances at the time.

The case amplified national debate over qualified immunity and police responses to mental health crises. Civil rights advocates criticized the ruling as a barrier to accountability, while law enforcement groups viewed it as necessary protection for officers making split-second decisions. It contributed to legislative discussions on police reform and alternative crisis intervention models.