U.S. Court of Appeals for the Eleventh Circuit

Rafael Cendan v. Officer Jose Trujillo

September 4, 2026

Summary

The Eleventh Circuit affirmed the district court’s summary‑judgment grant of qualified immunity to the officers for the period during which Rafael Cendan was resisting arrest, holding that he failed to demonstrate a clearly established Fourth Amendment right for that phase. Consequently, the court declined to reach the merits of his excessive‑force claim. The opinion also notes that the district court’s handling of the Heck v. Humphrey issue was unnecessary because qualified immunity independently supported the judgment.