The Eighth Circuit Court of Appeals reversed a federal district court's denial of qualified immunity to Missouri State Trooper Dylon Wyatt in a Section 1983 excessive force lawsuit involving the use of a police canine during an arrest.
In the case *Dukeman v. Wyatt*, decided Feb. 12, 2026, the three-judge panel unanimously ruled in favor of the state trooper, reversing the U.S. District Court for the Eastern District of Missouri's interlocutory order and remanding with instructions to dismiss all claims against Wyatt.
The lawsuit stems from a Nov. 8, 2020 incident in which John Phillip Wright Dukeman, II was arrested following a pursuit by Ste. Genevieve County sheriff's deputies. According to court records, Sergeant Charles Ochs and other county deputies pursued Dukeman for allegedly stealing a school bus in violation of Missouri state law.
Dukeman filed the federal civil rights lawsuit under 42 U.S.C. § 1983 against multiple defendants, including Ste. Genevieve County, the county sheriff's department, several deputies including Gary Stolzer, Richard Placke, Charles Ochs, and Trevor Green, as well as Missouri Highway Patrol Trooper Dylon Wyatt. The plaintiff alleged that the officers used excessive force when a Ste. Genevieve County police canine was deployed to facilitate his arrest.
The case centers on the qualified immunity doctrine, which protects government officials from civil liability when their conduct does not violate clearly established statutory or constitutional rights. Qualified immunity serves as a defense for law enforcement officers unless their actions violated rights that were clearly established at the time of the alleged misconduct.
Trooper Wyatt appealed the district court's denial of his motion to dismiss based on qualified immunity. The Eighth Circuit noted that federal appellate courts have jurisdiction to review interlocutory orders denying qualified immunity when the appeal turns on issues of law, citing the recent precedent *Arnold v. McClinton* (8th Cir. 2024).
Circuit Judge Bobby E. Erickson authored the opinion for the panel, which also included Chief Judge Steven M. Colloton and Circuit Judge David R. Stras. The court applied the de novo standard of review, meaning it examined the legal questions without deferring to the district court's analysis.
The appeals court's decision to reverse and remand with instructions to dismiss represents a complete victory for Trooper Wyatt. Such specific remand instructions typically indicate that the appellate court found the claims against the defendant legally insufficient and not subject to further factual development.
While the published portion of the opinion does not detail the specific factual allegations or legal reasoning behind the reversal, the outcome suggests the Eighth Circuit determined either that Wyatt's conduct did not violate the plaintiff's constitutional rights or that any rights violation was not clearly established at the time of the incident.
The case highlights ongoing tensions in federal civil rights litigation regarding police use of force, particularly involving canine units. Courts must balance the legitimate law enforcement need to apprehend suspects with constitutional protections against excessive force under the Fourth Amendment's reasonableness standard.
Qualified immunity doctrine has faced increased scrutiny in recent years, with critics arguing it provides too broad protection for law enforcement officers. However, the Supreme Court has maintained the doctrine while occasionally clarifying its application, most recently in cases involving use of force scenarios.
The Eighth Circuit's jurisdiction covers Arkansas, Iowa, Minnesota, Missouri, Nebraska, North Dakota, and South Dakota. The court's decision in this case may influence how similar police canine deployment cases are analyzed within the circuit.
For Dukeman, the ruling eliminates one defendant from his lawsuit but leaves claims against the county, sheriff's department, and individual deputies intact. Those defendants may pursue their own qualified immunity defenses or other motions to dismiss as the case proceeds in district court.
The case was submitted to the appeals court on Nov. 19, 2025, and decided approximately three months later on Feb. 12, 2026. This timeline reflects typical processing for interlocutory appeals, which receive expedited review due to their impact on ongoing litigation.
The reversal underscores the high bar plaintiffs face in Section 1983 excessive force cases against law enforcement officers. Even when district courts deny qualified immunity, appellate courts frequently reverse such denials, particularly when the legal standards governing police conduct were not clearly established at the time of the alleged misconduct.
As the case returns to district court, the remaining defendants will likely continue to litigate the excessive force allegations. The outcome may depend on specific factual findings about the circumstances of the canine deployment and whether the force used was reasonable under the totality of circumstances surrounding Dukeman's arrest.