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A Fatal Struggle: The Case of Nicholas Gilbert and the Complexity of Excessive Force

September 11, 2024

On the evening of December 8, 2015, Nicholas Gilbert was apprehended by St. Louis law enforcers for intruding into a condemned structure and neglecting to attend Court for a traffic infringement. Gilbert was transported to the St. Louis Metropolitan Police Department's leading site and placed in a secure compartment. Subsequently, what unfolded would result in a disputatious legal dispute and prompt crucial inquiries about the use of force by law authorities.

Gilbert, who was 5 feet 3 inches tall and weighed 160 pounds, was observed fastening a piece of fabric around the bars of his compartment and wrapping it around his throat in an evident suicide bid. Three law enforcers promptly intervened, entering Gilbert's compartment to subdue him. A scuffle broke out as Gilbert resisted an officer's effort to handcuff him, kicking and flailing. The officers succeeded in positioning him on his knees over a concrete bench and handcuffing his hands at the back. Despite being constrained, Gilbert persisted in resisting, kicking one officer in the private area, prompting a request for additional aid and leg restraints.

With six officers on site, they relocated Gilbert to a prone position, face down on the compartment floor. Three officers exerted pressure on his limbs and at least one on his back and midsection. Gilbert, having difficulty breathing, begged, "It hurts. Stop." After 15 minutes, Gilbert's motions ceased, and his breathing became irregular. Officers rolled him onto his side and then his back, discovering no pulse. They administered chest compressions and life-saving breaths until an ambulance arrived, but Gilbert was declared deceased at the hospital.

Gilbert's parents submitted a legal case, claiming the officers utilized too much force. The County Court allowed a summarised decision in favor of the officers, mentioning qualified immunity and expressing that no constitutional privilege was set up. The U.S. Court of Appeals for the Eighth Circuit affirmed that the officers' behaviors were not unreasonably excessive.

Evaluating unreasonable force allegations involves deciding whether the officers' behaviors were "objectively rational" given the circumstances. This rule, established in Graham v. Connor (1989), needs a detailed analysis of various aspects: the necessity for force, the degree of force employed, the scope of the injury, attempts to moderate the force, the safety threat, and whether the person resisted. The Eighth Circuit referred to these aspects but left ambiguity concerning the application of prone restriction and its constitutionality under persistent resistance.

The Supreme Court canceled the Eighth Circuit's decision, sending the case back for a more comprehensive examination considering the details and circumstances. This ruling underscored the value of context-specific analysis, as mandated by precedent in excessive force situations.

Justice Alito, dissenting, argued that the Eighth Circuit used the right rule and understood the case correctly, indicating that the Court's return was avoidable. He observed that the Eighth Circuit grasped the aspects and context needed for excessive force allegations. The Court should have refused the appeal or provided a complete review rather than annulling the ruling.

The lawsuit of Nicholas Gilbert underlines the intricate nature of unreasonable force complaints, where every detail and context holds significant importance. It also showcases the ongoing controversy over law enforcement processes, the boundaries of force, and the necessity for meticulous judicial examination to guarantee justice and responsibility. As legal criteria grow, the Gilbert lawsuit serves as a crucial reminder of the equilibrium between sustaining order and recognizing individual rights.

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Maithili Salunkhe

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