Stringer v. Cnty. of Bucks, 141 F.4th 76 (June 18, 2025) Krause, Circuit Judge.
When hauled into federal court, state actors undoubtedly want qualified immunity at the earliest possible stage. But how soon is too soon? We consider in this interlocutory appeal whether to deny a motion to dismiss on qualified immunity grounds where the complaint is sufficiently detailed to state a claim for a constitutional violation but not specific enough to assess whether the right was clearly established at the time it was allegedly violated.
In spring 2020, Plaintiffs Martha and Paul Stringer received news that any parent would dread: Their daughter, Kimberly, who had long struggled with severe mental illness, had been detained after an altercation with a neighbor and was being mistreated by the staff of the Bucks County Correctional Facility (BCCF), where she was being held. After Kimberly was finally transferred to a mental hospital and then released, the Stringers sued the County of Bucks and various BCCF corrections officers on Kimberly’s behalf,1 alleging that the officers’ actions—which included pepper spraying Kimberly and subjecting her to a restraint chair—violated her Fourteenth Amendment right to be free from excessive force. The District Court concluded the Stringers sufficiently pleaded a violation of Kimberly’s Fourteenth Amendment rights and denied Defendants’ motion to dismiss, reasoning that a more developed factual record was needed to ascertain whether the Defendants were entitled to qualified immunity.
We agree. While the Stringers’ complaint states a claim for a violation of a constitutional right, namely, Kimberly’s right to be free from the use of excessive force, it is not sufficiently detailed to enable the Court to define that right with more specificity and then assess whether that right was clearly established, as required for qualified immunity. Because the District Court correctly determined that Defendants’ entitlement to qualified immunity is not clear from the face of the complaint, we will affirm and remand for limited discovery as needed for a fact-specific qualified immunity analysis.
In sum, because “resolution of the qualified immunity of [Defendants] is not possible” until “the record is . . . expanded,” the District Court “correctly determined that dismissal on a 12(b)(6) motion in this case was premature and that the case would be better decided on summary judgment.” Schrob, 948 F.2d at 1421. We “express no opinion” on the objective reasonableness of Defendants’ actions because the District Court “is in a better position to resolve these issues on a motion for summary judgment after supplementation of the record.” Instead, “[b]ecause the record before us is insufficient for determination of [Defendants’] claim of qualified immunity, . . . we will remand to the district court for further development of the record” with respect to that defense. Brown v. United States, 851 F.2d 615, 617 (3d Cir. 1988).
We will affirm the District Court’s order denying the motion to dismiss on qualified immunity grounds without prejudice and remand with instructions for the District Court to conduct limited discovery tailored to uncovering those facts needed to rule on Appellants’ immunity defense.
