Danielle Arthur v. Douglas Krause

Summary

The court affirmed summary judgment for the corrections officers because Arthur was not subjected to a Fourth Amendment seizure during the voluntary hostage-training exercise. The officers intended to practice a rescue maneuver, not to restrain Arthur, and they never acquired actual control over her through a show of authority. The court also held that any error in granting summary judgment before resolving Arthur's sanctions motion was harmless because the alleged misconduct could not alter the dispositive, undisputed facts.