Nicholas Bolton v. Sheriff of Coweta County, GA

── Nicholas Bolton v. Sheriff of Coweta County, GA ── Court: Court of Appeals for the Eleventh Circuit Date: May 21, 2026 Category: NEW USCA11 Case: 23-12752 Document: 64-1 Date Filed: 05/21/2026 Page: 1 of 13 FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 23-12752 ____________________ NICHOLAS S. BOLTON, Plaintiff-Appellant, versus SHERIFF OF COWETA COUNTY, GA, JOHN TAYLOR COLLINS, Individually and in his official capacity as a former Deputy Sheriff for Coweta County, Georgia, CHRISTIAN SPINKS, individually and in his official capacity as a Deputy Sheriff of Coweta County, Georgia, JON HOUSE, individually and in his official capacity as a former Deputy Sheriff for Coweta County, Georgia, Defendants-Appellees. USCA11 Case: 23-12752 Document: 64-1 Date Filed: 05/21/2026 Page: 2 of 13 2 Opinion of the Court 23-12752 ____________________ Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:21-cv-02279-MHC ____________________ Before WILLIAM PRYOR, Chief Judge, ABUDU, Circuit Judge, and CONWAY,* District Judge. WILLIAM PRYOR, Chief Judge: This appeal requires us to decide whether three deputies and a sheriff are immune from a complaint of excessive force. Nicholas Bolton fled in his sport utility vehicle after Deputies John Collins and Jon House asked him to produce identification. The deputies pursued Bolton, performed a pursuit intervention technique to stop his vehicle, and then pinned his vehicle between several police cars. As Bolton continued to accelerate, Deputy Collins fired a sin- gle shot, which struck Bolton in the eye. Deputy Christian Spinks then removed Bolton from the vehicle, placed him on the ground, and handcuffed him while pressing a knee on Bolton’s back. Bolton sued the deputies for excessive force under the Fourth Amend- ment, see 42 U.S.C. § 1983, and the sheriff for supervisory liability, and he sued the deputies for assault and battery under state law. The district court granted summary judgment for the defendants. Because the deputies did not violate Bolton’s constitutional rights * The Honorable Anne C. Conway, United States District Judge for the Middle District of Florida, sitting by designation. USCA11 Case: 23-12752 Document: 64-1 Date Filed: 05/21/2026 Page: 3 of 13 23-12752 Opinion of the Court 3 or act with malice, and the sheriff enjoys sovereign immunity, we affirm. I. BACKGROUND We recount the events as depicted in the officers’ undis- puted bodycam videos. See Scott v. Harris, 550 U.S. 372, 380–81 (2007). Where the videos are unclear, we view the evidence in the light most favorable to Bolton as the nonmovant. See Baxter v. San- tiago-Miranda, 121 F.4th 873, 878 (11th Cir. 2024). On June 30, 2019, at around 2:30 a.m., Nicholas Bolton was in the backseat of his Tahoe vehicle in the parking lot of a shopping center. Deputy John Collins of the Coweta County Sheriff’s Office approached the vehicle, identified himself, and asked for Bolton’s identification. Bolton repeatedly ques