Fourth Amendment violation claims under 42 USC § 1983; “Probable cause” to arrest based on a reasonable ground to believe that plaintiff had committed felonious assault; “Excessive force”; Qualified immunity; Whether defendants-deputies violated a “clearly established” right; Whether Michigan’s law against “strip searches” (MCL 764.25a(3)) applied; Municipal liability claim based on a failure to train; Monell v. Department of Soc Servs of City of New York; Michigan law claims for false arrest & false imprisonment; Ethnic-intimidation claim under MCL 750.147b(1); Intentional infliction of emotional distress (IIED)

[This appeal was from the ED-MI.] The court held that defendants-deputies were entitled to summary judgment on plaintiff-Farris’s Fourth Amendment and Michigan state law claims. They had probable cause to arrest her where they had a reasonable belief that she had committed felonious assault. Further, she could not show that the force used to remove her from the police vehicle or to control her when placing her in a cell violated clearly established law. Farris got into a confrontation with a friend in which she was accused of waving either a knife or scissors. The deputies discovered a pocketknife and scissors in her car. While in the police vehicle, she attempted suicide with the seatbelt. She had to be forcibly removed from the vehicle. She told police during a pat-down that she was pregnant. She was released without charges the next day, but miscarried. Farris sued several deputies for excessive force under § 1983 and sued defendant-County for failure-to-train under Monell. She also brought Michigan state law claims. The district court granted defendants summary judgment. Her Fourth Amendment claim alleged that two separate groups of deputies committed two separate seizures when arresting and jailing her. The deputies asserted qualified immunity. The court held that the police had probable cause to arrest her. The alleged victim’s oral and later written statements and the presence of the knife and scissors in Farris’s car supported the arrest. Her excessive-force claim based on her removal from the police vehicle failed where she did not have analogous case law to establish that under the circumstances, the deputies’ specific actions violated a clearly established right. The court held that “Farris’s suicidal and uncooperative conduct gave the officers legitimate reasons for the minor force they employed, and our precedent would not have clearly established its illegality.” The court also held that MCL 764.25a(3) was not violated by the presence of male deputies when she refused to remove her clothes because the incident did not constitute a “strip search” where they removed her “street clothes” under a County “change-out” policy. As to Farris’s municipal liability claim based on a failure to train, the court held that she failed to establish a “specific constitutional violation” in her own case. She also fell short of showing that the County was deliberately indifferent to the use of excessive force. Her state-law claims for false arrest and imprisonment failed given that there was probable cause for her arrest. Her claims of assault and battery and IIED failed where the deputies were protected by governmental immunity under Michigan law. Finally, the court rejected her claim of ethnic intimidation under Michigan law where there was no evidence of discrimination based on her sex or her race. Affirmed.