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11th Circuit Rules on Police Excessive Force During Mental Health Crisis

The U.S. Court of Appeals for the Eleventh Circuit issued a published decision in Castro-Reyes v. City of Opa-Locka, addressing police use of force during a mental health emergency. The case involves allegations that four Florida police officers used excessive force while detaining Jafet Castro-Reyes under the state's Baker Act.

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4 min readcourtlistener
Seal of the Eleventh Circuit Court of Appeals

Case Information

Case No.:
24-12307

Key Takeaways

  • Eleventh Circuit issued published decision in police excessive force case during mental health crisis
  • Four Opa-Locka officers allegedly tased, punched, and dragged suspect during Baker Act detention
  • Case involves family members who initially restrained Castro-Reyes before calling 911
  • Published opinion suggests court established important precedent for mental health crisis response

The U.S. Court of Appeals for the Eleventh Circuit has issued a published decision in *Castro-Reyes v. City of Opa-Locka*, addressing police use of force during a mental health crisis response. The case centers on allegations that four Opa-Locka police officers used excessive force while detaining plaintiff Jafet Castro-Reyes under Florida's Baker Act.

According to court documents filed Feb. 6, 2026, the case involves an incident where Castro-Reyes experienced what the court described as "an episode of erratic behavior" at his apartment in Opa-Locka, Florida. The situation became so concerning that Castro-Reyes's friend and family members restrained him using electrical wires and clothing cords, binding his hands and feet before calling 911 for assistance.

When police responded to the emergency call, they detained Castro-Reyes under Florida's Baker Act, which allows for involuntary examination of individuals believed to be mentally ill and potentially dangerous. The Baker Act, codified in Florida Statutes sections 394.451 and 394.463(1), permits law enforcement to detain individuals for up to 72 hours for psychiatric evaluation when certain criteria are met.

The central dispute in the case arose during the officers' attempt to handcuff Castro-Reyes. According to the court record, a struggle allegedly ensued during which the officers tased, punched, and dragged Castro-Reyes. These actions form the basis of Castro-Reyes's excessive force claims against the individual officers.

Following his release from the hospital, Castro-Reyes filed a federal civil rights lawsuit against the City of Opa-Locka and four individual officers: German Bosque, Daniel Kelly, Luis Serrano, and Sergio Perez, all members of the Opa-Locka Police Department. The defendants appealed an adverse district court ruling to the Eleventh Circuit.

The case was heard by a three-judge panel consisting of Circuit Judges Hull, Marcus, and Wilson, with Judge Hull authoring the opinion. The appeal stems from the U.S. District Court for the Southern District of Florida, where the case was originally filed under docket number 1:22-cv-21397-KMW.

The Eleventh Circuit's decision to publish the opinion suggests the court views the case as establishing important precedent regarding police use of force in mental health situations. Published opinions carry greater precedential weight and provide guidance for future cases involving similar circumstances.

The case highlights ongoing tensions between law enforcement practices and mental health crisis response protocols. The Baker Act detention authority grants police significant power to intervene in mental health emergencies, but officers must still comply with constitutional limits on the use of force, even when dealing with individuals experiencing psychiatric crises.

The involvement of family members in initially restraining Castro-Reyes before police arrival adds complexity to the case, as it demonstrates the severity of his condition while potentially affecting the reasonableness analysis of the officers' subsequent actions. Courts typically evaluate excessive force claims under the Fourth Amendment's reasonableness standard, considering factors such as the severity of the threat posed, the immediacy of that threat, and whether the suspect was actively resisting or attempting to evade arrest.

Mental health advocates have long argued for specialized crisis intervention training for law enforcement officers, emphasizing de-escalation techniques and the involvement of mental health professionals in crisis response. The outcome of cases like *Castro-Reyes* can influence policy discussions about how police departments train officers to handle mental health emergencies.

The City of Opa-Locka, located in Miami-Dade County, has faced scrutiny in recent years over its police department's practices. The city's involvement as a defendant alongside the individual officers means it could face municipal liability if the court finds constitutional violations occurred as a result of inadequate policies, training, or supervision.

The case also raises questions about qualified immunity, a legal doctrine that protects government officials from civil lawsuits unless they violated clearly established constitutional rights. The doctrine has faced increased scrutiny in recent years, particularly in excessive force cases involving police officers.

While the full details of the Eleventh Circuit's ruling are not available from the partial court record, the decision to publish the opinion indicates the court addressed significant legal questions regarding police use of force in mental health contexts. The ruling will likely influence how similar cases are litigated in the Eleventh Circuit's jurisdiction, which covers Alabama, Florida, and Georgia.

The case represents part of a broader national conversation about police reform, mental health crisis response, and the appropriate limits on law enforcement authority when dealing with vulnerable populations. As courts continue to grapple with these issues, decisions like *Castro-Reyes* help establish the legal framework governing police conduct in mental health emergencies.

Topics

civil rightsSection 1983 claimexcessive forcefalse arrestqualified immunityBaker Act detentionpolice misconduct

Original Source: courtlistener

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