Benton V. Layton: Case Summary

Case Details:

Full Title:

LATOYA K. BENTON, Administrator of the Estate of Xzavier D. Hill, Deceased, Plaintiff, v. SETH W. LAYTON, individually and in his official capacity as State Trooper for the Virginia State Police, et al., Defendants.

Court:

United States District Court, Eastern District of Virginia

Date of Judgment: May 30, 2023

Case Summary:

Facts:

This case arises from the tragic death of Xzavier D. Hill (“Hill” or the “Deceased”). On January 9, 2021, Virginia State Troopers Seth W. Layton (“Layton”) and Benjamin I. Bone (“Bone”) (collectively, “Defendants” or the “Troopers”), tried to initiate a traffic stop on Hill’s vehicle, which was traveling at 96 miles per hour, well over the posted speed limit. Hill did not stop and led the Troopers on a high-speed chase for several miles, ending with Hill wrecking his vehicle in the median.

The Troopers approached the immobilized vehicle and provided Hill with several commands. Hill allegedly disregarded the Troopers’ instructions and eventually reached for a handgun. In response, the Troopers fired shots killing Hill. Latoya K. Benton (“Plaintiff’), Hill’s mother, brings this wrongful death and civil rights case as the Administrator of the Deceased’s estate against Layton and Bone. 

Issue:

Plaintiff alleges that the Troopers used excessive and unreasonable deadly force against Hill in violation of his rights under the U.S. Constitution. (Pl.’s Mem. in Opp’n at 19.) The Troopers argue that the force used was not excessive or objectively unreasonable under the circumstances and that the Troopers are entitled to qualified immunity. (Defs.’ Mem. in Supp. at 14.) Because the determination of whether the Troopers violated Hill’s constitutional rights is a component of the qualified immunity analysis, the Court will analyze both arguments under the rubric of its qualified immunity analysis below.

Decision:

The events that took place on January 9, 2021, were devastating and tragic, and the Court recognizes the public’s sensitivity to issues of law enforcement and the use of force. However, under the circumstances the Troopers faced, their conduct was not excessive as a matter of law, and the state of the law regarding the issues presented is clear. Therefore, for the foregoing reasons, the Court will grant Defendants’ Motion for Summary Judgment. An appropriate Order will accompany this Memorandum Opinion.

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