Law360 (May 15, 2026, 8:01 PM EDT) -- The Sixth Circuit has ruled that a Louisville Metropolitan Police Department officer is shielded by qualified immunity from a civil rights lawsuit filed against the officer after he shot and killed an armed-robbery suspect who had driven his car into police during a traffic stop.

The three-judge panel, reversing the lower court, found that Officer Bryan Arnold was entitled to qualified immunity from both state and federal law claims brought by the family of D'Juantez Mitchell, who claim that police were not justified in using deadly force against Mitchell.

"In some cases, concluding an official's actions were objectively reasonable and legally justified may not end the inquiry. After all, an official could still have acted with a corrupt or malicious motive; a person may act objectively reasonable yet still do so with impermissible intentions," U.S. Circuit Judge Richard Allen Griffin wrote in the opinion. "But here, plaintiffs fail to present evidence from which we may reasonably infer that Arnold's subjective motives were contrary to the objective justification of his actions."

Police identified Mitchell as being connected to a string of six gas station armed robberies that occurred in the Louisville, Kentucky, area between April and May 2019. Surveillance video from two of the gas stations showed suspects driving off in a white Kia Spectra with a missing hubcap, the opinion said.

Law enforcement was able to trace the vehicle to Mitchell, and police began searching for the vehicle. Arnold and his partner eventually located the car and observed Mitchell driving erratically and speeding, the panel said.

Arnold and his partner were in an unmarked police car when they pulled up alongside the white Kia. The officers illuminated the lights on the police car and drew their weapons as they walked toward Mitchell's car, the opinion said.

Arnold and his partner were standing at opposite ends of the vehicle, with Arnold standing near the front driver's side wheel, when they ordered Mitchell to turn off the car. Mitchell did not, and after another officer arrived, allegedly revved the car's engine, driving it into Arnold, the panel said.

Arnold immediately began firing his gun, which was pressed against the windshield on the driver's side. He continued to fire until the car struck the unmarked police car and stopped moving, the opinion said.

Police gave Mitchell first aid at the scene but could not revive him. Arnold's injuries from being hit by the car did not require medical treatment, the opinion said.

Mitchell's estate and family filed a federal lawsuit against the LMPD, Arnold, and two now-former chiefs of police alleging excessive force and a failure to train officers. The lawsuit asserted violations of both federal and state law.

Arnold moved for summary judgment on all the claims, and a federal judge in Kentucky granted him immunity on the federal law claims. The court found there was a genuine dispute over the facts surrounding the shooting under the state law claims related to whether Arnold acted in good faith during the shooting.

Arnold appealed the partial denial of his qualified immunity claims, telling the Sixth Circuit that the shooting was performed within the scope of his job. The Sixth Circuit agreed, finding that Mitchell's family was required to prove with direct evidence that Arnold fired the shots in bad faith, the opinion said.

The panel found that only Arnold's subjective views about the shooting and how he felt were at issue in the district court, and there was a lack of objective direct evidence. The lack of evidence means Arnold is entitled qualified immunity, the judges said.

An attorney representing Mitchell's family and estate and a spokesperson for the Jefferson County attorney's office did not respond to a requests for comment.

U.S. Circuit Judges Jeffrey Sutton, Richard Allen Griffin and John Nalbandian sat on the panel for the Sixth Circuit.

Mitchell's estate and family are represented by Hal D. Friedman of Cooper & Friedman PLC and by Gregory Simms of Simms Law Office.

The government is represented by Kristie B. Walker, Richard Elder and Andrew S. Miller of the Jefferson County Attorney's Office.

The case is Mitchell et al. v. Conrad et al., case number 25-5405, in the U.S. Court of Appeals for the Sixth Circuit.

--Editing by Linda Voorhis.

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