Ronald Young v. Eric Keyes

── Ronald Young v. Eric Keyes ── Court: Court of Appeals for the Eighth Circuit Date: May 19, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-2763 ___________________________ Ronald Edward Young Plaintiff - Appellant v. Eric Keyes, acting in his individual capacity as a Williston police officer; Nick Rintamaki, acting in his individual capacity as a Williston police officer Defendants - Appellees ____________ Appeal from United States District Court for the District of North Dakota - Western ____________ Submitted: October 22, 2025 Filed: May 19, 2026 ____________ Before SMITH, KELLY, and GRASZ, Circuit Judges. ____________ SMITH, Circuit Judge. Williston Police Officer Eric Keyes saw Ronald Young make an illegal turn and pulled him over. Officer Keyes questioned Young and had him exit his vehicle. After Officer Keyes administered a series of field-sobriety tests, Young and Officer Keyes began arguing. Eventually, Officer Keyes, with the assistance of Officer Nick Rintamaki, took Young to the ground and handcuffed him. Young was injured in the struggle. He subsequently sued Officers Keyes and Rintamaki for excessive force. The district court granted the officers’ motion to dismiss on the grounds of qualified immunity. Young now appeals. We reverse and remand. I. Background At approximately 10:00 p.m. on December 31, 2019, New Year’s Eve, Officer Keyes witnessed a vehicle making an illegal left turn and initiated a traffic stop. During his conversation 1 with the driver, Young, Officer Keyes “observed indicia of alcohol intoxication” and conducted field-sobriety tests. R. Doc. 1, at ¶ 10. The officers conducted two tests. However, during the second, Young ceased complying with Officer Keyes’s directions. After Officers Keyes and Rintamaki completed the two tests, Officer Keyes requested another screening test using an alcohol sensor. Young declined to answer whether he would agree to the test and instead continued asking questions. Officer Keyes then told Young, “I am done arguing with you.” R. Doc. 17, at 3 (quoting R. Doc. 10-2, at 16:27). Young responded, “no,” while stepping toward Officer Keyes. Id. (quoting R. Doc. 10-2, at 16:27). Young’s complaint describes the next series of events as follows: 12) Without warning, Keyes forcefully grabbed Young’s arm. 13) After Keyes grabbed Young’s arm, he then commanded Young to put his hands behind his back. 14) Rintamaki grabbed Young from the other side. 15) Both officers threw Young to the ground. Because the officers held Young’s arms, Young was unable to protect himself from injury as he was thrown to the ground. 16) Young repeatedly asked officers what they were doing to him. 1 The district court relied on dash-camera and body-camera footage, finding that they were “embraced by the pleadings.” R. Doc. 17, at 2 (citing Ching v. City of Minneapolis, 73 F.4th 617, 621 (8th Cir. 2023)). The parties do not object to the use of the videos or their authenticity. -2-  17) Young tried to prevent injury to himself during the encounter, but officers controlled him and prevented him from doing so. 18) The officers put their weight on Young’s back once he was on the ground. Officers continued to control and put Young’s arms into a painful position. R. Doc. 1, at ¶¶ 12–18. The video footage does not contradict Young’s allegations. The dash