⚖ Oral Arguments, with Context

The Sixth Circuit hears Jonathan Sellars' appeal from the dismissal of his excessive-force lawsuit. His family sought help during a mental-health crisis at his Tennessee home. Officers tried to take him to a hospital, he resisted, and a deputy punched him in the face during the encounter. Sellars sued the deputy and Sumner County. He later pleaded guilty to resisting arrest and assaulting a first responder. The district court concluded that his resisting-arrest conviction prevented the federal civil claim from going forward. The lawsuit uses Section nineteen eighty-three, a federal law allowing people to seek redress for violations of federal rights by officials acting under state authority. But Heck versus Humphrey imposes a limit: a civil damages claim cannot proceed if winning would necessarily undermine a still-valid criminal conviction. The important word is necessarily. Admitting resistance does not automatically answer every question about the amount of force an officer may use. Tennessee law makes the distinction important. An unlawful arrest alone is generally not a defense to resisting arrest. A separate self-defense provision has two requirements: the officer uses more force than necessary, and the person reasonably believes resistance is immediately necessary to protect against that force. An affirmative defense is a legal justification that can excuse conduct otherwise treated as criminal. The dispute is whether success on this civil claim would necessarily establish both requirements. Bryan Moseley will argue for Sellars that his resistance was not self-defense against the punch, so the conviction and civil claim can coexist. Tom Russell, for the deputy and county, will argue that the force and resistance were one inseparable struggle and that the guilty plea bars the suit. Listen also for the judges' questions about whether Sellars adequately presented his argument in his opening appeal brief. Allowing the case to proceed would not itself decide whether the punch was unlawful.

Jonathan Sellars v. Sumner County, Tennessee (No. 26-5256) — U.S. Court of Appeals for the Sixth Circuit, argued October 22, 2026.