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Michael Handt v. Rick Lynch; Floyd County, Iowa

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Submitted: December 13, 2011

Before LOKEN, MURPHY, and SHEPHERD, Circuit Judges.

After suffering a month-long incarceration that was not ordered by a state court, plaintiff Michael Handt brought this 42 U.S.C. § 1983 action, alleging that his federal and state constitutional rights were violated when the defendants unlawfully seized, searched, and detained him. Steve Koffron, Mark Jacobsen, Steve Takes, and Carrie Carson (collectively “defendants”) moved for summary judgment on the basis of qualified immunity. The district court denied their motion for summary judgment. Defendants now seek interlocutory review of that decision. Because the district court failed to complete the qualified immunity analysis, we vacate the district court’s order and remand for a thorough consideration of the defendants’ claim that they are entitled to qualified immunity.

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