Officer Given Qualified Immunity Even When Acting Against His Training

The Eleventh Circuit seems to have broadened the reach of qualified immunity for government officials. Dukes v. Nicholas, No. 15-14373, 2017 WL 370854 (11th Cir. Jan. 26, 2017). In Dukes, officers were serving a search warrant on an apartment. Id. at *1. The plan called for two of the officers to throw flashbang grenades to disorient the occupants. Id. All other officers also had the flashbang grenades and could use them as needed. Id. at *2. A third officer, with seemingly no purpose, threw a flashbang through a window of the apartment. Id. The flashbang landed near an occupant, causing severe burns. Id. The officer testified that he was trained to never throw a flashbang grenade witho

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