Toni Mitchell v. Steve Conrad

── Toni Mitchell v. Steve Conrad ── Court: Court of Appeals for the Sixth Circuit Date: May 14, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0146p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ TONI MITCHELL, Administratrix of the Estate of │ D’Juantez Mitchell; COURTNEY JEWELL-MOORE, │ Guardian, Mother, and Next Friend of KMM, KCM, │ JLM, and JAM, minors, │ Plaintiffs-Appellees, > No. 25-5405 │ │ v. │ │ STEVE CONRAD, │ Defendant, │ │ │ BRYAN ARNOLD, individually and in his official │ capacity as a Law Enforcement Officer for the │ Louisville Metro Police Department, │ Defendant-Appellant. │ ┘ Appeal from the United States District Court for the Western District of Kentucky at Louisville. No. 3:20-cv-00530—David Jason Hale, District Judge. Argued: March 18, 2026 Decided and Filed: May 14, 2026 Before: SUTTON, Chief Judge; GRIFFIN, and NALBANDIAN, Circuit Judges. _________________ COUNSEL ARGUED: Kristie B. Walker, JEFFERSON COUNTY ATTORNEY’S OFFICE, Louisville, Kentucky, for Appellant. Hal D. Friedman, COOPER & FRIEDMAN, PLC, Louisville, Kentucky, for Appellees. ON BRIEF: Kristie B. Walker, Richard Elder, Andrew S. Miller, JEFFERSON COUNTY ATTORNEY’S OFFICE, Louisville, Kentucky, for Appellant. Hal D. Friedman, COOPER & FRIEDMAN, PLC, Louisville, Kentucky, Gregory Simms, SIMMS LAW OFFICE, Louisville, Kentucky, for Appellees.  No. 25-5405 Mitchell, et al. v. Conrad, et al. Page 2 _________________ OPINION _________________ GRIFFIN, Circuit Judge. Defendant Bryan Arnold, a law enforcement officer, initiated a traffic stop of D’Juantez Mitchell, who was suspected of committing several armed robberies. During the stop, Mitchell drove his car into Arnold and towards a fellow officer. In response, Arnold shot and killed Mitchell. Mitchell’s estate and children dispute that Arnold was justified in using deadly force and sued, alleging that Arnold had violated Mitchell’s rights under both the United States Constitution and Kentucky law. The district court found that Arnold was entitled to qualified immunity under federal law but not entitled to immunity under Kentucky law after concluding that the record created a genuine dispute whether Arnold acted in good faith. Because the evidence presents no triable issue regarding a bad faith motive on Arnold’s part, we reverse. I. A. In April and May of 2019, an armed individual robbed six gas stations throughout the Louisville metropolitan area. In each instance, the perpetrator entered the business, violently brandished a fir