The U.S. Court of Appeals for the Ninth Circuit affirmed a district court's summary judgment ruling against David Henry in his civil rights lawsuit targeting two Tacoma police officers and the city. The decision, filed Jan. 16, 2026, rejected Henry's appeal of constitutional violation claims arising from his 2021 arrest.
Henry brought the lawsuit under 42 U.S.C. Section 1983, the federal civil rights statute that allows individuals to sue government officials for constitutional violations committed under color of state law. The defendants included Tacoma Police Officers Ron Komarovsky and Brynn Cellan, as well as the City of Tacoma.
The case originated from events on Jan. 6, 2021, when Henry caused a traffic collision at an intersection in Tacoma, Washington. According to court records, Henry ran a red light and collided with another vehicle that was lawfully passing through a green light on the intersecting road. Officers Komarovsky and Cellan responded to the scene of the accident.
The court noted that many of the relevant events were captured on Officer Komarovsky's body-worn camera, providing visual documentation of the incident. Witnesses at the scene told the responding officers that they observed Henry run the red light before the collision occurred.
Henry's Section 1983 lawsuit alleged that the officers violated his constitutional rights during or following his arrest. However, the specific nature of the alleged constitutional violations was not detailed in the available court documents. Section 1983 claims commonly involve allegations of excessive force, unlawful seizure, false arrest, or other violations of Fourth Amendment protections.
The case proceeded through the U.S. District Court for the Western District of Washington, with District Judge Tiffany M. Cartwright presiding. The district court ultimately granted summary judgment in favor of the defendants, finding that Henry had not established sufficient evidence to support his constitutional violation claims.
Summary judgment is granted when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. For Henry to survive summary judgment on his Section 1983 claims, he would have needed to present evidence that the officers acted unreasonably under the circumstances and that their conduct violated clearly established constitutional rights.
Henry appealed the district court's ruling to the Ninth Circuit Court of Appeals. The three-judge panel consisted of Circuit Judges Richard Paez, William Bennett, and Michelle Sung. The court reviewed the case under the de novo standard, meaning it considered the legal issues fresh without deference to the lower court's conclusions.
The Ninth Circuit panel unanimously concluded that the case was suitable for decision without oral argument, indicating that the legal issues were sufficiently clear that additional argument would not materially assist the court's deliberations. This procedural decision reflects the court's assessment that the appeal lacked merit warranting extended consideration.
In affirming the district court's summary judgment ruling, the Ninth Circuit effectively validated the lower court's conclusion that Henry's evidence was insufficient to establish a viable Section 1983 claim. The appeals court cited *Lowry v. City of San Diego*, a 2017 en banc Ninth Circuit decision, in support of its de novo review standard for such cases.
The ruling represents another instance where federal courts have rejected civil rights claims against police officers following traffic-related incidents. Section 1983 litigation against law enforcement faces significant hurdles, including qualified immunity protections for officers and the requirement that plaintiffs demonstrate violations of clearly established constitutional rights.
The decision was issued as a memorandum opinion marked "not for publication," meaning it will not serve as binding precedent for future cases. However, under Ninth Circuit Rule 36-3, such dispositions may still have limited precedential value in certain circumstances.
The case file shows the district court case number as 3:22-cv-05523-TMC, indicating Henry filed his lawsuit in 2022, approximately one year after the underlying incident occurred. The appeal was docketed as No. 24-3014, suggesting Henry appealed the summary judgment ruling in 2024.
For Henry, the ruling represents the end of his federal civil rights claims against the Tacoma officers and the city, absent any further appeal to the Supreme Court. The decision joins numerous other cases where federal courts have found insufficient evidence to support constitutional violation claims against police officers in traffic-related encounters.
The body-worn camera footage mentioned in the case likely played a role in the court's analysis, as such recordings frequently provide crucial evidence in determining whether officers' actions were reasonable under the circumstances. The availability of witness testimony corroborating that Henry ran the red light may have further undermined any claims that his subsequent arrest was unlawful.
The ruling underscores the challenges civil rights plaintiffs face in establishing constitutional violations in cases involving routine police responses to traffic violations, particularly when objective evidence supports the officers' version of events.