Lombardo v. St. Louis
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Lombardo v. St. Louis and why it matters. Quotes are taken from the syllabus (the Courtās short summary at the start of the opinion).
Summary
A short, plain-English overview of Lombardo v. St. Louis.
The Supreme Court vacated and remanded the Eighth Circuit's decision in Lombardo v. St. Louis, questioning whether the use of prone restraint was per se constitutional. The case involves the death of Nicholas Gilbert after being restrained by police officers. The Court emphasized the need for a context-specific analysis of excessive force claims.
Holding
The single most important ābottom lineā of what the Court decided in Lombardo v. St. Louis.
The Court held that the Eighth Circuit's judgment is vacated and the case is remanded for further consideration consistent with the Court's excessive force precedent.
Constitutional Concepts
These are the Constitution-related themes that appear in Lombardo v. St. Louis. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Lombardo v. St. Louis
The case involves the question of whether the officers' actions were objectively reasonable, which implicates procedural due process in terms of fair treatment under the law.
Syllabus excerpt (verbatim)In assessing a claim of excessive force, courts ask 'whether the officers' actions are 'objectively reasonable' in light of the facts and circumstances confronting them.'
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Why Cruel and Unusual Punishment is relevant to Lombardo v. St. Louis
The case discusses whether the use of force was excessive, which relates to the prohibition of cruel and unusual punishment.
Syllabus excerpt (verbatim)The Court expresses no view as to whether the officers used unconstitutionally excessive force or, if they did, whether Gilbert's right to be free of such force in these circumstances was clearly established at the time of his death.
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Why Substantive Due Process is relevant to Lombardo v. St. Louis
The case involves the substantive question of whether the force used was excessive, impacting fundamental rights.
Syllabus excerpt (verbatim)Such a per se rule would contravene the careful, context-specific analysis required by this Court's excessive force precedent.
Key Quotes
Short excerpts from the syllabus in Lombardo v. St. Louis that support the summary and concepts above.
The Eighth Circuit's judgment is vacated, and the case is remanded.
The inquiry requires careful attention to the facts and circumstances of each particular case.
We express no view as to whether the officers used unconstitutionally excessive force.
