St. Louis

Judge Tosses St. Louis No-Knock Raid Suit In Deadly SWAT Shooting

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Published on February 16, 2026
Judge Tosses St. Louis No-Knock Raid Suit In Deadly SWAT ShootingSource: Unsplash/ Sasun Bughdaryan

A federal judge has sided with the City of St. Louis and several police officers, granting summary judgment on Feb. 13 and shutting down, at least for now, a civil lawsuit over a no-knock warrant that preceded a 2017 SWAT raid that left Don Clark Sr. dead. Clark's family had argued that officers relied on false or misleading information to get the warrant and then used excessive force during the entry. The ruling resolves the federal claims at the district court level and spells out how the judge viewed the evidence and the governing legal standards.

What the judge ordered

U.S. District Judge Joshua M. Divine issued a memorandum and order granting the defendants' motion for summary judgment, finding that the Clark family did not present evidence creating a genuine dispute that Detective Thomas Strode lacked probable cause or that Officer Nicholas Manasco was required to refrain from using deadly force. The opinion walks through the court's analysis of probable cause and qualified immunity. The full memorandum is available in the federal docket via Justia Dockets & Filings.

The 2017 raid that spurred the lawsuit

The case traces back to Feb. 21, 2017, when officers executed search warrants at three homes on the 4000 block of California Avenue in south St. Louis. As part of that operation, officers breached 4023 California Avenue and used a diversionary device during the entry. According to prior reporting and the court record, Officer Nicholas Manasco then fired multiple rounds that killed 63-year-old Don Clark Sr. The raid and the affidavits that backed the warrants have drawn sustained local and national scrutiny, including an earlier investigation by The Washington Post.

Why the court sided with the city

In the memorandum, the court concluded that the family did not clear the legal hurdles required to show that Strode intentionally or recklessly inserted false statements into the warrant affidavit or that a reasonable officer in Manasco's position would have been obligated not to use deadly force. The judge applied the Franks standard for claims involving alleged falsehoods in warrant affidavits and evaluated qualified immunity under existing Eighth Circuit precedent. Based on that framework, the court held that the record did not justify sending the claims to a jury, as detailed in the filing linked above.

Policy backdrop and wider scrutiny

The decision lands against a shifting policy backdrop in St. Louis. In 2022, Mayor Tishaura O. Jones signed an executive order that barred the local police department from using no-knock entries, part of a broader reform push that followed several high-profile fatal raids. National reporting has highlighted instances in which no-knock warrants led to deadly confrontations while turning up only small quantities of drugs, a pattern that helped fuel tighter local and state limits on the tactic. For a local look at those changes, see coverage from St. Louis Public Radio and the Washington Post investigation cited earlier.

What comes next

The district court's dismissal ends the Clark family's federal civil claims for now, although options such as an appeal remain available. Local outlets have been unpacking the ruling and the reaction to it, including the St. Louis Post-Dispatch, which reported on the decision today, Feb. 16, 2026.