A three‑judge panel of the 9th U.S. Circuit Court of Appeals on Monday, Sept. 21, affirmed a district court’s decision denying qualified immunity to two Lane County Sheriff’s Office deputies. The case stems from the March 27, 2020 arrest of Eugene resident Landon Payne, 37, who died two days later while in custody.
Facts of the incident
According to court filings, Payne was first shocked with a Taser four or five times while lying prone. After being transported to the Lane County jail, deputies continued to restrain him, pressing their weight on his neck and torso despite his cries for air and an apparent lack of resistance. The lawsuit alleges that the deputies’ actions contributed to Payne’s death.
Court’s reasoning
In a 2‑1 decision, Judges M. Margaret McKeown and Jennifer Sung wrote that Payne’s “minor offenses, handcuffs, prone position, and the numerous officers surrounding him would permit a jury to find that he ‘posed only a minimal threat to anyone’s safety.’” They concluded that the factual dispute over whether the force used was objectively reasonable precluded granting summary judgment in the deputies’ favor.
Judge Sidney Fitzwater, sitting by designation, dissented. He cited his review of body‑camera and sally‑port video, arguing that the deputies should be granted immunity.
Background and legal context
Payne’s wife, Anzhelika “Angie” Payne, called 911 in 2020 after her husband experienced a mental‑health crisis and was believed to be under the influence of drugs. Police in Eugene reportedly arrested him based on an “unconfirmed” child‑support warrant. The lawsuit, filed by Angie Payne, also includes a negligence claim against the City of Eugene and remains pending in the U.S. District Court for the District of Oregon.
Implications for law‑enforcement accountability
The appellate ruling underscores the courts’ willingness to allow civil suits to proceed when there is a genuine dispute over the reasonableness of force. It signals to law‑enforcement agencies in Oregon and beyond that the use of Tasers and physical restraint, especially on individuals experiencing mental‑health crises, will be closely scrutinized.
Local officials and community leaders have long called for greater transparency and training in de‑escalation techniques. While the case does not resolve liability, it keeps the issue in the public eye and may influence future policy discussions within the Lane County Sheriff’s Office and the City of Eugene.
Next steps
The case will move forward to trial, where a jury will assess the evidence and determine whether the deputies’ conduct violated Payne’s constitutional rights. Both the plaintiffs and the defendants have indicated they will continue to present expert testimony on use‑of‑force standards and medical causation.
For residents of Lane County and the broader Oregon community, the decision serves as a reminder of the importance of vigilant oversight of public‑safety agencies, especially when vulnerable individuals are involved.
Original reporting: Homepage – Lookout Eugene-Springfield — read the source article.
