The U.S. Court of Appeals for the Sixth Circuit issued a ruling Thursday reversing a lower court's decision and granting qualified immunity to a Reynoldsburg police officer accused of using excessive force during an arrest warrant execution. The court held that Officer Nicholas Rubenstahl was entitled to qualified immunity protection in the excessive force lawsuit filed by Rebecca Lucas.
In *Lucas v. City of Reynoldsburg*, the Sixth Circuit panel consisting of Circuit Judges Gibbons, Larsen, and Murphy unanimously reversed the district court's denial of Rubenstahl's motion for summary judgment. Circuit Judge Larsen wrote the opinion for the court, which was filed Jan. 23, 2026, and marked as not recommended for publication.
The case stems from events in 2022 when Lucas became the subject of criminal charges following neighbor complaints. A neighbor initially accused Lucas of tampering with a "no trespassing" sign in her yard and filed a complaint against her with local authorities. Based on this complaint, an arrest warrant was issued for Lucas on the misdemeanor offense of criminal mischief.
Officer Rubenstahl first attempted to serve the arrest warrant on Lucas by going to her home, but he was unable to make contact with her during that initial visit. The situation escalated the following day when the same neighbor returned to the police station to file an additional report about Lucas.
According to court documents, the neighbor reported that a dispute had developed over Lucas's "aggressive" dogs. The neighbor also alleged that Lucas had "mooned" the neighbor during their confrontation. The court opinion indicates there were additional allegations made by the neighbor, though the full details of the second complaint are not completely outlined in the available portion of the decision.
When Officer Rubenstahl subsequently executed the arrest warrant, Lucas alleged that he used excessive force during the encounter. She filed a lawsuit against both Rubenstahl individually and the City of Reynoldsburg, claiming her constitutional rights were violated during the arrest.
Rubenstahl responded to the lawsuit by filing a motion for summary judgment, asserting that he was entitled to qualified immunity protection. Qualified immunity is a legal doctrine that protects government officials, including police officers, from civil liability when their actions do not violate clearly established law that a reasonable person would have known.
The U.S. District Court for the Southern District of Ohio initially denied Rubenstahl's motion for summary judgment based on qualified immunity. This denial allowed Lucas's excessive force claims to proceed toward trial, prompting Rubenstahl to appeal the decision to the Sixth Circuit.
On appeal, the Sixth Circuit panel disagreed with the district court's analysis and concluded that Officer Rubenstahl was indeed entitled to qualified immunity protection. The appeals court found that under the specific circumstances of this case, Rubenstahl's actions during the warrant execution did not violate clearly established constitutional law.
The qualified immunity doctrine requires courts to engage in a two-part analysis. First, courts must determine whether the facts alleged show that an officer violated a constitutional right. Second, if a violation occurred, courts must assess whether the right was clearly established at the time of the alleged violation, such that a reasonable officer would have understood that their conduct was unlawful.
The Sixth Circuit's reversal indicates that either Lucas failed to demonstrate a constitutional violation occurred, or that any violation did not involve clearly established law that would have put a reasonable officer on notice that their conduct was prohibited.
This decision represents another example of federal appellate courts applying qualified immunity protection to shield police officers from excessive force claims. The doctrine has been the subject of ongoing legal and policy debates, with critics arguing it provides too much protection for police misconduct, while supporters contend it appropriately balances officer accountability with the need to protect officials making split-second decisions in difficult circumstances.
The case also highlights the complexities that can arise when police officers execute arrest warrants for misdemeanor offenses, particularly in situations involving ongoing neighbor disputes and multiple complaints. The involvement of "aggressive" dogs and the reported confrontational behavior between neighbors created a challenging environment for law enforcement intervention.
For Lucas, the Sixth Circuit's reversal effectively ends her excessive force claims against Officer Rubenstahl, as qualified immunity provides complete protection from civil liability. The ruling does not address any potential claims against the City of Reynoldsburg, which would be analyzed under different legal standards.
The opinion was designated as "not recommended for publication," meaning it will have limited precedential value for future cases. However, it contributes to the ongoing body of qualified immunity jurisprudence in the Sixth Circuit, which covers federal courts in Ohio, Michigan, Kentucky, and Tennessee.
The case number is 25-3481, and the decision was issued on appeal from the U.S. District Court for the Southern District of Ohio. No further appeals are indicated in the available court records.