James P. Crocker v. Deputy Sheriff Steven Eric Beatty

Steven Beatty, a deputy in the Martin County (Florida) Sheriff's Office, appeals the District Court's denial of his motion for summary judgment as to one claim in James Crocker's complaint against him. Crocker brought suit under 42 U.S.C. § 1983 , asserting that his Fourth Amendment rights were violated when Beatty seized his iPhone after Crocker took photos and videos of a car accident crash scene from an interstate grass median (the phone seizure claim). The District Court determined that this seizure constituted a Fourth Amendment violation and that Beatty was not entitled to qualified…