FIGUEROA v. SANTA ROSA COUNTY SHERIFF DEPARTMENT (2026)

ORDER GRANTING DEFENDANT DANIELS'S MOTIONS FOR SUMMARY JUDGMENT

This case arises out of the purported mental health seizures of two autistic children at a school in Santa Rosa County. Plaintiffs include the minor children, C.B. and B.F., who have sued Defendant David Daniels, the former sheriff's deputy who took them into custody. C.B.'s remaining claim against Defendant Daniels is for a violation of his Fourth Amendment rights to be free from unreasonable seizures, brought under section 1983. B.F. also alleges a section 1983 claim for a violation of his right to be free from unreasonable seizures and a separate section 1983 claim for excessive force. Defendant Daniels has now moved for summary judgment as to all three of these claims. ECF Nos. 181 and 182.

This Court has considered, without hearing, Defendant Daniels's motions for summary judgment, id., Plaintiffs' response in opposition, ECF No. 203, and Defendant Daniels's reply, ECF No. 209. For the reasons set out below, Defendant Daniels's motions, ECF Nos. 181 and 182, are GRANTED.

This Court will address each motion in turn, starting with the motion for C.B.'s Fourth Amendment claim, ECF No. 181. As for both motions, Defendant Daniels asserts the undisputed facts demonstrate he is entitled to qualified immunity as to all claims. An official asserting qualified immunity must first prove that he or she was acting within the scope of his or her “discretionary authority at the time of the alleged constitutional violation.” Morris v. Town of Lexington, 748 F.3d 1316, 1321 n.15 (11th Cir. 2014). In this case, Plaintiffs do not dispute that Defendant Daniels acted within his discretionary authority when he handcuffed C.B. and B.F. as part of the purported mental health seizures that took place in November and December 2021. The burden, therefore, shifts to Plaintiffs to establish (1) a violation of a constitutional or statutory right and (2) that the right was clearly established when the violation in question occurred. See Pearson v. Callahan, 555 U.S. 223, 232, 129 S.Ct. 808, 172 L.Ed.2d 565 (2009) (citations omitted).

With respect to C.B.'s remaining Fourth Amendment claim, the issue is whether a reasonable jury could find, based on this record, that Defendant Daniels violated C.B.'s right to be free from unreasonable seizures when he took C.B. into custody under Florida's Baker Act statute on November 10, 2021, and whether, as a matter of law, that right was clearly established. Defendant Daniels originally argued that the seizure did not violate C.B.'s Fourth Amendment rights because he had probable cause to seize C.B. under Florida's Baker Act, and even if he did not have probable cause to initiate a Baker Act, he had probable cause to arrest C.B. for other offenses, which precludes C.B.'s Fourth Amendment claim. The parties' briefing as to whether probable cause to arrest C.B. for a suspected criminal offense immunizes Defendant Daniels's potentially wrongful seizure under the Baker Act lacked any meaningful citation to authority. This Court's own research identified at least one published, out-of-circuit decision that reached the opposite conclusion. See Guan v. City of New York, 37 F.4th 797, 807 (2d Cir. 2022) (“We hold that the existence of probable cause to arrest an individual for a criminal violation does not preclude a false arrest claim based on a wrongful arrest for a mental health evaluation.”). However, Defendant Daniels has now filed a notice of supplemental authority, ECF No. 214, discussing a recent, binding decision from the Eleventh Circuit that holds that an officer is entitled to qualified immunity for a mental health seizure when the officer has probable cause to arrest the individual for a criminal offense. See Marbut v. Phillips, 176 F. 4th 1256, 1266 (11th Cir. 2026) (“Even if the emergency-aid doctrine did not justify a seizure, the officers could seize Marbut because they had probable cause to believe she committed a criminal offense.”).

Although the Eleventh Circuit offered no explanation for why the “any crime” rule immunizes officers who may have otherwise wrongfully conducted a mental health seizure, this Court is bound to follow this holding. Here, Plaintiff C.B. does not dispute that Defendant Daniels had probable cause to arrest C.B. for battery on a law enforcement officer based on C.B.'s attempt to push past Defendant Daniels, who was blocking the door after C.B. had just attempted to run outside. See ECF No. 181 at 20. This is clearly depicted in the body camera footage. ECF No. 77-4 at 00:40–00:50. Inasmuch as Defendant Daniels has demonstrated no dispute of material fact with respect to whether he had probable cause to arrest C.B. for this battery, this Court is bound to follow Marbut and conclude that Defendant Daniels is entitled to qualified immunity for the seizure of C.B. on November 10, 2021.¹ In so stating, this Court need not reach Defendant's new argument, in light of Marbut, that his actions in conducting the purported mental health seizure were arguably objectively reasonable. See ECF No. 214 (notice of supplemental authority). Accordingly, on this narrow basis, Defendant Daniels's motion for summary judgment, ECF No. 181, is GRANTED as to C.B.'s individual-capacity claim against him.

Next, this Court considers Defendant Daniels's motion for summary judgment with respect to Plaintiff B.F.'s Fourth Amendment seizure and excessive force claims, ECF No. 182. As for the wrongful seizure claim, Defendant Daniels also asserts the undisputed facts demonstrate that he had probable cause to arrest B.F.—an eight-year-old boy with autism—for battery on a school official and thus he is entitled to qualified immunity for his decision to seize B.F. under the Baker Act on December 8, 2021. Id. at 17. Plaintiff B.F. does not dispute the underlying facts with respect to the alleged battery on a school official. See ECF No. 203 at 20 (“Earlier that morning, B.F. punched Ms. Madison once in the stomach with a closed fist ․”). Plaintiff B.F.'s only rebuke to this argument is that Defendant Daniels could not have arrested B.F. for this battery because the school's policy did not permit school staff to pursue criminal charges against students. Id. at 46. But Defendant Daniels correctly points out that the decision to arrest and prosecute is vested in the State, notwithstanding a disinterested alleged victim. In other words, an alleged victim's decision not to press charges does not prevent a law enforcement officer from making an arrest otherwise supported by probable cause. Accordingly, the school's policy forbidding school staff from pressing charges does not eliminate the probable cause Defendant Daniels had to arrest B.F. for battery on a school official. As a result, Defendant Daniels is entitled to qualified immunity with respect to B.F.'s Fourth Amendment seizure claim pursuant to Marbut.²

B.F. also brings an excessive force claim against Defendant Daniels, which this Court must analyze separately notwithstanding the fact that Defendant Daniels had probable cause to arrest B.F. Castro-Reyes v. City of Opa-Locka, 166 F.4th 886, 900 (11th Cir. 2026) (“Even when an officer has probable cause to arrest or detain an individual, the individual may still pursue a § 1983 excessive force claim if the force used to effectuate the arrest or detention was objectively unreasonable.”). This Court previously determined that Defendant Daniels had not demonstrated qualified immunity with respect to this claim at the pleading stage. ECF No. 94 at 21–25. Now this Court considers the issue again with the benefit of a developed record, although this Court notes that the pertinent facts largely consist of the same materials before this Court at the motion-to-dismiss stage—namely, the body camera footage depicting Defendant Daniels's use of force. ECF Nos. 77-1 and 77-2.

Defendant Daniels contends that the record demonstrates, without dispute, that the level of force he used was objectively reasonable under the totality of the circumstances. With respect to B.F.'s claim, “whether a constitutional violation occurred is governed by the Fourth Amendment's ‘objective reasonableness’ standard.” Hadley v. Gutierrez, 526 F.3d 1324, 1329 (11th Cir. 2008). Under this standard, this Court asks “whether the officers' actions are objectively reasonable in light of the facts and circumstances confronting them, without regard to their underlying intent or motivation.” Graham v. Connor, 490 U.S. 386, 397, 109 S.Ct. 1865, 104 L.Ed.2d 443 (1989) (internal quotation omitted).³ In assessing the reasonableness of the force used, a court must “balance the risk of bodily harm to the suspect against the gravity of the threat the officer sought to eliminate.” Terrell v. Smith, 668 F.3d 1244, 1251 (11th Cir. 2012) (internal quotation omitted). While each inquiry is fact-specific, relevant factors to examine include “the severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the officers or others, and whether [the suspect] is actively resisting arrest or attempting to evade arrest by flight.” Lee v. Ferraro, 284 F.3d 1188, 1197–98 (11th Cir. 2002) (quoting Graham, 490 U.S. at 396, 109 S.Ct. 1865). “A student's age, size, and behavioral issues may affect the reasonableness inquiry.” G.D.M. ex rel. T.E.M. v. City of Oviedo, Fla., 2026 WL 1298153, at *6 (11th Cir. May 11, 2026) (citing Gray ex rel. Alexander v. Bostic, 458 F.3d 1295, 1305–06 (11th Cir. 2006)).

The first Graham factor weighs in B.F.'s favor. It is now undisputed that B.F. struck a teacher within moments of his being handcuffed. But he was also a small, unarmed child whose physical strikes are unlikely to amount to serious injury. Indeed, the body camera footage shows the teacher laughing off the suggestion of taking B.F. to jail for the strike.

The second factor weighs in B.F.'s favor for the same reason. A small eight-year-old with no access to weapons could not pose a serious threat to an able-bodied adult. The record demonstrates that B.F. had no access to weapons and at the time of this incident, he had been removed from his classroom and was surrounded by three adults—two school employees and Defendant Daniels.

The third factor is a closer call, because B.F. twice wriggled free of the handcuffs and resisted Defendant Daniels's attempt at control throughout his interaction with B.F. However, the record permits a reasonable inference that B.F.'s wriggling free from the handcuffs was not an attempt to escape detention as a whole, but B.F.'s response to the handcuffs causing severe pain.⁴ Indeed, when B.F.'s arm was freed, he did not attempt to run away from Defendant Daniels or school staff, nor did he try and strike any of the adults present. Instead, B.F. remained seated where he was and pleaded for “one more chance.” It is reasonable for this Court to infer that B.F. removed his arm from the handcuff in an effort to alleviate his pain—not to escape.

In short, the Graham factors all appear to favor B.F. This Court concluded as much at the motion to dismiss stage. However, from that early stage the record has developed and now it is less clear whether Defendant Daniels's rough handcuffing and manhandling of a small, distraught child with autism was objectively unreasonable, given his violent outburst toward a teacher in the Defendant's presence and the requirement that he be handcuffed for transportation. See, e.g., G.D.M., 2026 WL 1298153 at *7 (holding that handcuffing a nine-year-old and controlling his movements only until he stopped exhibiting aggressive behavior and relaxed was a de minimis use of force).

Assuming arguendo that Defendant Daniels violated Plaintiff B.F.'s Fourth Amendment rights by handcuffing him in this way, Plaintiff B.F. has not shown that his right not to be handcuffed in this manner was clearly established. At the motion-to-dismiss stage, this Court previously compared the allegations in this case to the circumstances at issue in Gray, concluding that the allegations permitted a reasonable inference that the purpose of the handcuffing was punitive, rather than legitimate, and that the right to be free from handcuffing for merely punitive purposes was clearly established. But Gray involved a case where there was no legitimate purpose for the seizure or the use of force, and that the officer handcuffed a small child only for punitive reasons. Here, on the other hand, there is no genuine dispute of material fact as to whether Defendant Daniels had probable cause to arrest and handcuff B.F. for battery on a school official. And Defendant Daniels was required to handcuff for safe transport. Moreover, the body camera footage demonstrates that the handcuffing was “rough” at least in part because Plaintiff B.F. was distraught and resistant to Defendant Daniels's attempt at control. While the handcuffing included gratuitous commentary from both Defendant Daniels and school staff regarding “consequences,” indicating a motivation toward punishment, Gray does not clearly establish that Defendant Daniels's decision to handcuff a resistant, mentally-disabled little boy who had just hit his teacher was unconstitutional. Indeed, in G.D.M. the Eleventh Circuit only recently determined that handcuffing and restraining a nine-year-old in the midst of a behavioral meltdown constituted de minimis force and no constitutional violation at all. See 2026 WL 1298153 at *8. And Plaintiff B.F. has identified no case on point or principle of law that would have been obvious to any reasonable officer that handcuffing an eight-year-old who had just battered a teacher in the officer's presence in this manner was unconstitutional, particularly when the Sheriff's policy required handcuffing for safe transport. Accordingly, Defendant Daniels has demonstrated that he is entitled to qualified immunity as to B.F.'s excessive force claim.

To be clear, this Court is not deciding that Defendant Daniels's actions were wise or right or that any of the adults involved behaved the way one would want if it were their child in the “Serenity Room,” instead of C.B. or B.F. That is not the question for this Court, for if it were, the outcome would be much different given the troubling treatment, taunts, and other commentary directed at both children. This Court does not wish to gloss over the fact that the body camera footage from both events is deeply disturbing. Instead, this Court must determine whether Defendant Daniels knowingly violated the law when he handcuffed both children for the purported mental health seizures. See Ashcroft v. al-Kidd, 563 U.S. 731, 743, 131 S.Ct. 2074, 179 L.Ed.2d 1149 (2011) (“Qualified immunity gives government officials breathing room to make reasonable but mistaken judgments about open legal questions. When properly applied, it protects ‘all but the plainly incompetent or those who knowingly violate the law.’ ”) (quoting Malley v. Briggs, 475 U.S. 335, 341, 106 S.Ct. 1092, 89 L.Ed.2d 271 (1986))). And, on this record, Plaintiffs have not identified a dispute of material fact or legal argument that would defeat his entitlement to qualified immunity.

IT IS ORDERED:

1. Defendant Daniels's motions for summary judgment, ECF Nos. 181 and 182, are GRANTED insofar as Defendant Daniels is entitled to qualified immunity as to Counts I and II of the Second Amended Complaint, ECF No. 74.

2. This Court does not direct entry of judgment on the issues decided in this Order under Federal Rule of Civil Procedure 54(b).

SO ORDERED on September 3, 2026.

FOOTNOTES

1.   Inasmuch as Defendant Daniels has established probable cause to arrest C.B., this Court need not apply the “less exacting reasonableness standard” usually applied to seizures of children in the school setting. See Richmond v. Badia, 47 F.4th 1172, 1181 n.1 (11th Cir. 2022).

2.   Again, inasmuch as Defendant Daniels has established probable cause to arrest B.F., this Court need not apply the “less exacting reasonableness standard” usually applied to seizures of children in the school setting. See Richmond, 47 F.4th at 1181 n.1.

3.   This Court recognizes that Graham is not a perfect analogue, because there was no “arrest” pursuant to a criminal statute in this case. Instead, there was a detention pursuant to the Baker Act. However, the parties rely on Graham standards and this Court therefore analyzes the incident under Graham. Further, the Eleventh Circuit has applied Graham to Baker Act detentions. See, e.g., Weiland v. Palm Beach Cnty. Sheriff's Off., 792 F.3d 1313 (11th Cir. 2015).

4.   As this Court previously noted in its Order on the motion to dismiss, should this inference be called into question, this Court implores a reviewing court to review the body camera footage, which appears to show B.F.'s hand losing circulation and becoming discolored as a result.

Mark E. Walker, United States District Judge