The Second Circuit Court of Appeals issued a decision in *Matusak v. Daminski*, addressing whether Monroe County Sheriff's Office deputies are entitled to qualified immunity after a jury found they used excessive force during an arrest.
Christopher Matusak filed the appeal following a district court judgment after jury trial. The case stems from Matusak's arrest on Feb. 1, 2018, in Scottsville, New York, where he fled from police officers.
The defendants in the case are Deputy Matthew Daminski, Deputy Stephen Murphy, and Sergeant Brian Unterborn, all employees of the Monroe County Sheriff's Office. During the arrest, the officers employed a combination of fist and knee strikes, pepper spray, and a taser before placing Matusak in handcuffs.
Matusak sued the officers under 42 U.S.C. § 1983, alleging violations of his Fourth and Fourteenth Amendment rights through the use of excessive force during the arrest. The case proceeded to a jury trial in the U.S. District Court for the Western District of New York before Judge Payson.
Following the trial, the jury made a series of determinations regarding the officers' conduct. Significantly, the jury found that two officers from the Monroe County Sheriff's Office used excessive force against Matusak during the arrest. However, the jury also found that Deputy Daminski did not use excessive force.
After receiving the jury's answers to a series of questions, the district court granted the officers' motion for judgment as a matter of law. The trial court determined that despite the jury's finding of excessive force by two officers, the defendants were entitled to qualified immunity protection.
Qualified immunity is a legal doctrine that protects government officials from liability for civil damages unless their conduct violated clearly established statutory or constitutional rights that a reasonable person would have known. The doctrine requires courts to determine whether the alleged facts, taken in the light most favorable to the plaintiff, show that the defendant's conduct violated a constitutional right, and whether that right was clearly established at the time of the alleged violation.
Matusak appealed the district court's qualified immunity determination to the Second Circuit Court of Appeals. The appeal was argued on Oct. 9, 2025, before a three-judge panel consisting of Chief Judge Livingston, Circuit Judge Wesley, and District Judge Wolford.
Chief Judge Elizabeth A. Wolford of the U.S. District Court for the Western District of New York sat by designation on the appellate panel. The Second Circuit issued its decision on Jan. 29, 2026.
The case highlights ongoing tensions between law enforcement practices and constitutional protections against excessive force. Fourth Amendment jurisprudence requires that police use of force be objectively reasonable under the circumstances, considering factors such as the severity of the crime, whether the suspect poses an immediate threat, and whether the suspect is actively resisting or attempting to flee.
The Fourteenth Amendment's Due Process Clause also provides protection against excessive force, particularly in situations where the Fourth Amendment may not apply. Courts must analyze whether the force used was conscience-shocking or demonstrated deliberate indifference to the suspect's constitutional rights.
Section 1983 claims allow individuals to seek monetary damages and injunctive relief against state and local officials who violate their constitutional rights under color of state law. These lawsuits serve as an important mechanism for holding law enforcement accountable for misconduct.
The qualified immunity doctrine has been subject to increasing scrutiny in recent years, with critics arguing it provides too much protection for government officials and makes it difficult for victims of misconduct to obtain relief. Supporters contend that the doctrine is necessary to prevent excessive litigation that could inhibit officials from performing their duties.
The Second Circuit's decision in *Matusak* adds to the body of case law addressing when officers may claim qualified immunity protection in excessive force cases. The court's analysis of the jury's findings and the district court's legal conclusions will provide guidance for future cases involving similar fact patterns.
The ruling affects how courts in the Second Circuit will evaluate qualified immunity claims in excessive force cases, particularly where juries have made specific factual determinations about officer conduct. The decision may also influence how district courts handle post-trial motions for judgment as a matter of law in civil rights cases.
The case demonstrates the complex interplay between jury fact-finding and judicial legal determinations in civil rights litigation. When juries find constitutional violations but courts must still determine whether legal protections apply, appeals courts play a crucial role in ensuring proper application of legal standards.