Nicholas S. Bolton v. Lenn Wood, Sheriff, Coweta County, Georgia, et al.

Whether sheriff deputies are entitled to summary judgment based on qualified immunity in a federal § 1983 civil rights action despite evidence that the deputies investigated whether the plaintiff was loitering without seeking any relevant information; induced the plaintiff to leave the scene by threatening him with arrest and refusing to explain why he was instructed to exit from his parked vehicle; then aimed firearms at the plaintiff’s head before he drove away from the parking lot.

Whether sheriff deputies are entitled to summary judgment based on qualified immunity in a federal § 1983 civil rights action despite evidence that the deputies initiated an unauthorized vehicle chase of the plaintiff and immobilized his vehicle by performing a dangerous, unjustified, and unauthorized “precision immobilization technique” or “pursuit intervention tactic” (PIT maneuver).

Whether sheriff deputies are entitled to summary judgment based on qualified immunity in a federal § 1983 civil rights action despite evidence that the deputies used deadly force to shoot the plaintiff in the head without giving him a feasible advance warning or any opportunity to turn off his engine while he was sitting in an immobilized vehicle without posing a threat to anyone.

Whether a sheriff deputy is entitled to summary judgment based on qualified immunity in a federal § 1983 civil rights action despite evidence that he used excessive, unnecessary force on the critically wounded, helpless plaintiff.

Whether a county sheriff, sued in his official capacity, is entitled to summary judgment based on sovereign immunity in a federal § 1983 civil rights action despite evidence that he a) failed to train deputies to investigate a criminal offense, b) failed to enforce training to de-escalate potential conflicts with vehicle drivers, c) failed to enforce policies on vehicle pursuits, d) failed to enforce policies on PIT maneuvers, and e) failed to enforce policies on the use of deadly force.

Whether sheriff deputies are entitled to summary judgment on state law claims for assault and battery despite ample evidence that the deputies acted with actual malice and intent to injure the plaintiff.