Tenth Circuit Refines the Prone-Restraint Analysis

In Teetz v. Stepien, No. 23-1078 (10th Cir. June 2025), the court let an excessive-force claim proceed to trial after officers held a restrained juvenile facedown for roughly 30 minutes. Relying on Weigel (2008), the panel held that a reasonable jury could find the extended pressure objectively un-reasonable under clearly established law, so qualified immunity was unavailable at summary judgment. Key doctrinal points:

• Force that is reasonable at the initial takedown can become excessive once control is secure

• Prolonged weight on a restrained, prone suspect may be deemed “deadly force” if it creates a substantial risk of serious harm

• The qualified-immunity inquiry looks to both the duration of force and evolving medical understanding of positional asphyxia