Rayshawn Walden v. City of Detroit, Mich.

── Rayshawn Walden v. City of Detroit, Mich. ── Court: Court of Appeals for the Sixth Circuit Date: May 20, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0224n.06 Case No. 25-1919 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED May 20, 2026 KELLY L. STEPHENS, Clerk ) RAYSHAWN WALDEN, ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE EASTERN CITY OF DETROIT, MICHIGAN, ) DISTRICT OF MICHIGAN Defendant, ) ) BAILEY RUMSCHLAG, ) OPINION ) Defendant-Appellant. ) Before: COLE, STRANCH, and BUSH, Circuit Judges. COLE, Circuit Judge. While on patrol, Detroit police officers Bailey Rumschlag and Jacob Patterson pulled into a gas station and saw Rayshawn Walden with a noticeable bulge under his t- shirt. Rumschlag exited the car and Walden ran. Rumschlag pursued Walden, shortly thereafter firing six shots, one of which hit Walden from behind. Walden sued Rumschlag and the City of Detroit, bringing excessive force and municipal liability claims under 42 U.S.C. § 1983 along with Michigan state-law claims. The defendants moved for partial summary judgment, which the district court denied. Rumschlag appeals the denial of qualified immunity. Because this appeal rests on a factual dispute, we dismiss for lack of jurisdiction. I. We review the denial of qualified immunity de novo. Peck v. Bridgeport Machs., Inc., 237 F.3d 614, 617 (6th Cir. 2001); Campbell v. Cheatham Cnty. Sheriff’s Dep’t, 47 F.4th 468, 475 (6th No. 25-1919, Walden v. City of Detroit, et al. Cir. 2022). At the interlocutory appeal stage, “ideally, we . . . look no further than the district court’s opinion for the pertinent facts and inferences.” Bunkley v. City of Detroit, 902 F.3d 552, 560 (6th Cir. 2018). Here, however, our review is constrained by the district court’s decision not to issue a written opinion. See Peck, 237 F.3d at 617. We may nonetheless consider the court’s reasoning as stated in the transcript of the summary judgment hearing. Id. During the hearing, the district court indicated that it had reviewed the evidence and thoroughly explained its basis for denying Rumschlag’s motion for summary judgment. And following the proceeding, the district court issued an order that incorporated its reasoning from the hearing and denied summary judgment. Further, when we possess video of an incident, as here, we view the facts “in the light depicted by any unambiguous footage.” Campbell, 47 F.4th at 475. But when the video contains “relevant gaps or uncertainties,” we must view those gaps “in the light most favorable to” the nonmoving party. LaPlante v. City of Battle Creek, 30 F.4th 572, 578 (6th Cir. 2022) (quoting Latits v. Phillips, 878 F.3d 541, 544 (6th Cir. 2017)). We thus draw the following facts from body camera footage and the hearing transcript. A. The relevant altercation is relatively brief, lasting just over a minute on video. Rumschlag pulled into the gas station parking lot because he saw the imprint of a