A federal appeals court has cleared the way for a Knoxville-area veteran’s civil-rights lawsuit against a Knox County sheriff’s deputy who allegedly mistook him for another man, chased him and hit him with a Taser, sending him face-first into the pavement. The ruling does not award damages, but it means Deputy Randall Williams cannot use qualified immunity to end Brian Hux’s claim that the stop itself was unconstitutional.
The Sixth Circuit Court of Appeals issued the decision last Wednesday, affirming a lower-court ruling that Williams could not claim qualified immunity on Hux’s Fourth Amendment unlawful-seizure claim. The Knoxville News Sentinel reported the development Wednesday.
The Deputy Was Looking For A Different Man
According to the Sixth Circuit’s opinion, Williams was searching for Matthew Messer after receiving a Knox County Sheriff’s Office BOLO. Messer was described as a 6-foot-tall, 34-year-old white man with long brown hair who was suspected of evading police after being placed on a hold pending treatment at the University of Tennessee Medical Center.
Williams encountered Hux in South Knox County on October 10, 2022. Hux was 64 years old, about 5 feet 9 inches tall, and had a beard, a mustache, and long hair that was purple near the roots and brown toward the ends, according to the court’s summary of the allegations.
Williams activated his emergency lights and moved toward Hux, shouting for him to come over. Hux asked what the deputy wanted and began moving away; Williams then ran after him with a Taser and fired when he was within roughly eight feet, the opinion says.
Judges Said The Stop Lacked Reasonable Suspicion
The Taser’s prongs struck Hux, causing him to seize up and fall onto the pavement. The court said Hux suffered serious injuries, including an intracranial hemorrhage and a skull-base fracture with associated narrowing of a major artery, and was taken to the intensive care unit at UTMC.
The appeals panel rejected Williams’ argument that the BOLO description and Hux’s appearance gave him enough reason to make an investigative stop. The judges emphasized that Hux’s age and other physical differences should have made clear that he was not the 34-year-old man described by dispatch.
Williams also argued that Hux’s running supplied reasonable suspicion. But the court said Hux did not flee until after Williams charged toward him, making the flight provoked rather than the kind of unprompted flight that can sometimes justify a police stop.
The panel also rejected the idea that a warrant mentioned during the encounter erased Hux’s right to challenge an unreasonable seizure. In its view, having a warrant or being suspected of a crime does not eliminate Fourth Amendment protections against an unlawful detention.
What The Ruling Does — And Does Not — Decide
The ruling is narrower than the headline might suggest. As outlined in a federal district court order, Hux’s excessive-force and battery claims against Williams were dismissed on qualified-immunity grounds, and those issues were not part of the appeal the Sixth Circuit decided.
That leaves Hux’s unlawful-stop claim alive, but it is not a final finding that Williams owes him money. The case can continue in federal court, where the parties may still litigate the underlying facts, damages, and any remaining claims.
The appellate opinion also recounts allegations that Hux was unable to live independently after the incident and that his vehicle was impounded and auctioned while he was recovering. Hux was quickly identified as the wrong person at UTMC, according to the court’s account, but the legal consequences of that mistaken stop are still unfolding.
.jpg){kind=link}