Marie Woolfolk, Administratrix of the Estate of Eric Rahmal Woolfolk Leroy and Marie Woolfolk v. Darren Smith City of Pine Bluff, Arkansas

Darren Smith, a newly-hired, off-duty, out-of-uniform police officer, chased suspect Eric Woolfolk on foot to make an arrest, cornered Woolfolk in a narrow carport where the two struggled, and shot and killed Woolfolk when he began hitting Smith in the head with a plastic trash can lid. Woolfolk’s parents then commenced this § 1983 action, asserting a Fourth Amendment excessive force claim against Smith and a failure-to-train claim against Smith’s employer, the City of Pine Bluff, Arkansas. The district court 1 denied defendants’ motion for summary judgment and they appeal, arguing that we…