Ted Acord v. Chad Stilley
Court
Fourth Circuit Court of Appeals
Decided
June 6, 2025
Jurisdiction
F
Practice Areas
Case Summary
USCA4 Appeal: 24-1934 Doc: 47 Filed: 06/06/2025 Pg: 1 of 3 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 24-1934 TED ACORD, as Administrator of the Estate of Michael Acord, Plaintiff – Appellant, v. CHAD STILLEY, Defendant – Appellee. Appeal from the United States District Court for the Western District of Virginia, at Roanoke. Elizabeth K. Dillon, Chief District Judge. (7:22-cv-00284-EKD-CKM) Argued: May 6, 2025 Decided: June 6, 2025 Amended June 6, 2025 Before KING, THACKER, and BERNER, Circuit Judges. Affirmed by unpublished per curiam opinion. ARGUED: Seth Raven Carroll, COMMONWEALTH LAW GROUP, PLLC, Richmond, Virginia, for Appellant. Jeremy E. Carroll, SPILMAN THOMAS & BATTLE, PLLC, Roanoke, Virginia, for Appellee. ON BRIEF: Julian F. Harf, SPILMAN THOMAS & BATTLE, PLLC, Roanoke, Virginia, for Appellee. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 24-1934 Doc: 47 Filed: 06/06/2025 Pg: 2 of 3 PER CURIAM: In this appeal from the Western District of Virginia, plaintiff Ted Acord, as Administrator of the Estate of Michael Acord, challenges the district court’s award of summary judgment to defendant Chad Stilley, a police officer with the Town of Narrows, Virginia. See Memorandum Opinion, Acord v. Stilley, No. 7:22-cv-00284 (W.D. Va. Sept. 20, 2024), ECF No. 62 (the “Summary Judgment Opinion”).* Ted Acord filed this civil action pursuant to 42 U.S.C. § 1983, alleging that Stilley used excessive force in violation of the Fourth Amendment, in that Stilley caused a fatal collision with Michael Acord, who was fleeing westbound through Stilley’s bailiwick — the Town of Narrows — on his motorcycle at a high rate of speed, by moving the police vehicle in which he sat into the public highway — that is, U.S. Route 460 — and blocking all lanes of escape. Acord also raised a claim of battery under Virginia state law. The court granted summary judgment to Stilley on both claims, concluding that he was entitled to qualified immunity on the federal claim and good-faith immunity under Virginia law on the state law claim. On appeal, Acord argues that Stilley’s conduct violated Michael’s clearly established constitutional rights and that the court therefore erred in awarding summary judgment in Stilley’s favor on both the federal and state law claims. Having carefully assessed the record and the parties’ briefs, and with the benefit of oral argument, we are satisfied that the district court did not err in determining that Stilley The district court’s Summary Judgment Opinion is published at 749 F. Supp. 3d * 635 (W.D. Va. 2024). 2 USCA4 Appeal: 24-1934 Doc: 47 Filed: 06/06/2025 Pg: 3 of 3 was entitled to qualified immunity as to Acord’s § 1983 claim asserting a Fourth Amendment violation. See Somers v. Devine, 132 F.4th 689, 695 (4th Cir. 2025). We are also satisfied that the court correctly determined that Stilley was entitled to good-faith immunity as to Acord’s state law battery claim. See Amisi v. Brooks, 93 F.4th 659, 674- 75 (4th Cir. 2024) (recognizing “the Virginia’s immunity doctrine is congruent with the federal qualified immunity defense” (internal quotation marks omitted)); see also Wingate v. Fulford, 987 F.3d 299, 312 (4th Cir. 2021). Indeed, we readily adopt the court’s thorough and well-reasoned Summary Judgment Opinion. We therefore reject Acord’s appellate contentions and affirm the final judgment of the district court. See Acord v. Stilley, No. 7:22-cv-00284 (E.D. Va. Sept. 20, 2024), ECF No. 63. AFFIRMED 3
Case Summary
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Case Overview
In Ted Acord v. Chad Stilley, the United States Court of Appeals for the Fourth Circuit addressed a civil rights claim involving excessive force and qualified immunity. The case arose from a tragic incident where Michael Acord was fatally injured during a police pursuit. Ted Acord, as the administrator of Michael's estate, appealed the district court's decision granting summary judgment in favor of police officer Chad Stilley.
Key Legal Issues
- Excessive Force under 42 U.S.C. § 1983
- Qualified Immunity for law enforcement officers
- State Law Battery claims under Virginia law
Court's Decision
On June 6, 2025, the Fourth Circuit affirmed the district court's summary judgment, concluding that Officer Stilley was entitled to both qualified immunity for the federal claim and good-faith immunity under Virginia law for the state claim. The court found no error in the district court's determination.
Legal Reasoning
The Fourth Circuit analyzed whether Stilley's actions constituted a violation of Michael Acord's Fourth Amendment rights. The court noted that:
- Acord was fleeing on a motorcycle at a high speed when Stilley maneuvered his police vehicle onto U.S. Route 460, blocking all escape routes.
- The district court had previously concluded that Stilley's actions did not amount to a constitutional violation that was clearly established at the time.
The court also addressed the state law claim, affirming that Stilley was entitled to good-faith immunity under Virginia law, which aligns with the principles of qualified immunity recognized in federal law.
Key Holdings
- Affirmation of Summary Judgment: The Fourth Circuit upheld the lower court's ruling, confirming that Stilley was entitled to qualified immunity.
- Good-Faith Immunity: The court recognized Stilley's entitlement to immunity under Virginia law for the battery claim.
Precedents and Citations
- Somers v. Devine, 132 F.4th 689 (4th Cir. 2025) - Established guidelines on qualified immunity in excessive force claims.
- Amisi v. Brooks, 93 F.4th 659 (4th Cir. 2024) - Discussed the congruence of Virginia's immunity doctrine with federal qualified immunity.
- Wingate v. Fulford, 987 F.3d 299 (4th Cir. 2021) - Provided context on immunity defenses applicable to law enforcement.
Practical Implications
This case underscores the complexities surrounding qualified immunity and the challenges plaintiffs face in proving excessive force claims against law enforcement. The ruling reinforces the legal protections afforded to police officers under both federal and state law, particularly in high-stakes situations involving pursuit and potential danger to the public. Legal practitioners should be aware of the stringent standards for overcoming qualified immunity in civil rights litigation and the importance of establishing clearly defined constitutional violations.
In summary, Ted Acord v. Chad Stilley serves as a significant case in the ongoing discourse on police accountability and civil rights, illustrating the judicial system's balancing act between protecting individual rights and safeguarding law enforcement officers from undue liability.
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Status
Decided
Date Decided
June 6, 2025
Jurisdiction
F
Court Type
appellate
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