The Supreme Court declined to shield a Grand Rapids police officer from a civil rights lawsuit stemming from a volatile moment during the 2020 George Floyd protests, allowing the case to proceed despite his invocation of qualified immunity.
Officer Phillip Reinink fired a tear gas canister during a May 30, 2020, disturbance just days after George Floyd's death in Minneapolis. The projectile struck Sean Hart in the shoulder, leaving him injured. Reinink claimed he believed his launcher held a powder form of tear gas meant for direct deployment, but the device was actually configured to fire canisters into the air.
A police department investigation determined that Reinink's use of force was unreasonable and resulted in a two-day suspension. Hart sued, claiming a violation of his Fourth Amendment rights against unlawful force.
The case turned on qualified immunity, the legal doctrine that typically shields officers from civil liability when enforcing the law. Officers win on these grounds with regularity, making Reinink's loss on this point significant. A federal judge in Michigan initially dismissed Hart's claim in March 2023, but the 6th U.S. Circuit Court of Appeals reversed that decision in May 2025, ruling that regardless of intent, the incident constituted deadly force. The court found Reinink would have been on notice that such force in that circumstance violated established law.
The Supreme Court's decision to let the appellate ruling stand marks a rare setback for police immunity arguments at the nation's highest court. Justices Clarence Thomas and Samuel Alito dissented in a separate note, saying they would have sided with Reinink.
The qualified immunity issue loomed large in the national reckoning that followed Floyd's death. Protesters and reform advocates targeted the doctrine as a primary obstacle to holding officers accountable for constitutional violations. Those reform efforts largely stalled in subsequent years, even as courts continued to shape how the doctrine applies in practice.
Author Sarah Mitchell: "This is the kind of narrow but meaningful crack in qualified immunity that actually matters, especially when it involves force that clearly crossed a line."
Comments