Sara Lowry v. City of San Diego

Sara Lowry was sleeping in the privacy of her office, when she was attacked and injured by a police dog trained to inflict harm on the first person it encounters. Because a reasonable jury could find that the City of San Diego’s use of a police dog was unreasonable under the circumstances presented here, I must respectfully dissent.

I

In my view, the district court erred in concluding that no reasonable jury could find that an excessive force constitutional violation had occurred. Under the Graham v. Connor framework, “[d]etermining whether the force used to effect a particular seizure is…