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Coffin v. Brandau

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[PUBLISH]

Before TJOFLAT and ANDERSON, Circuit Judges, and WOOD,*fn1 District Judge.

In this case, Cynthia Coffin attempted to shut her open garage door to prevent two Sarasota County Sheriff’s deputies, James Lutz and Stacy Brandau, from serving a court order on her husband, James Coffin.*fn2 Brandau stepped into the garage while the door was closing, breaking the electronic-eye safety beam on the garage door and causing the door to retreat to its open position. The Deputies, who did not possess a search or arrest warrant, entered the Coffins’ garage and subsequently arrested Mrs. Coffin for obstruction of justice.*fn3 The Coffins sought damages against Lutz and Brandau under 42 U.S.C. § 1983 on the ground that the Deputies’ warrantless entry into their garage and Mrs. Coffin’s arrest violated their Fourth Amendment rights.*fn4 The Deputies contended that qualified immunity shields them from liability, and the district court agreed, granting them summary judgment. The court concluded that the Deputies had violated the Coffins’ Fourth Amendment rights but were shielded by qualified immunity because the law governing “arrests at or just within the threshold of the house” was not clearly established until McClish v. Nugent, 483 F.3d 1231 (11th Cir. 2007) was decided.

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