What is the question presented in Rivas-Villegas v. Cortesluna?

1. Did the Ninth Circuit depart from this Court’s decisions in Graham v. Connor, 490 U.S. 386 (1989) and Plumhoff v. Rickard, 572 U.S. 765 (2014) in denying qualified immunity to petitioner based upon the absence of a constitutional violation, by concluding that pushing a suspect down with a foot and briefly placing a knee against the back of a prone, armed suspect while handcuffing him, could constitute excessive force? 2. Did the Ninth Circuit depart from this Court’s decision in Kisela v. Hughes, ___ U.S. ___, 138 S. Ct. 1148 (2018) (per curiam) and numerous other cases by denying qualified immunity even though two judges concluded the use of force was reasonable, and notwithstanding the absence of clearly established law imposing liability under circumstances closely analogous to those confronting petitioner?

What is Rivas-Villegas v. Cortesluna about?

This case asked whether a police officer could be sued for excessive force after he briefly put his knee on the back of a suspect who had a knife in his pocket while officers were disarming and handcuffing him during a domestic violence response. The Supreme Court held that the officer was entitled to qualified immunity because prior cases had not clearly established that this conduct was unconstitutional.

When did the Supreme Court decide Rivas-Villegas v. Cortesluna?

The Supreme Court decided Rivas-Villegas v. Cortesluna on October 18, 2021.

No. 20-1539October Term 2020Decided Oct 18, 2021Updated Sep 3, 2026

Docket 20-1539October Term 2020 (2020–2021)

Rivas-Villegas v. Cortesluna

Rivas-Villegas could not be sued for damages on this excessive-force claim because the law had not clearly established that his actions were unconstitutional.

Case status

Decided · October 18, 2021

Read the opinion (PDF)

Current stage: Decided
Latest event: Decision released Oct 18, 2021

Case Accepted

Arguments

Decision ReleasedOct 18, 2021

What it's about: This case asked whether a police officer could be sued for excessive force after he briefly put his knee on the back of a suspect who had a knife in his pocket while officers were disarming and handcuffing him during a domestic violence response. The Supreme Court held that the officer was entitled to qualified immunity because prior cases had not clearly established that this conduct was unconstitutional.
Question presented
1. Did the Ninth Circuit depart from this Court’s decisions in Graham v. Connor, 490 U.S. 386 (1989) and Plumhoff v. Rickard, 572 U.S. 765 (2014) in denying qualified immunity to petitioner based upon the absence of a constitutional violation, by concluding that pushing a suspect down with a foot and briefly placing a knee against the back of a prone, armed suspect while handcuffing him, could constitute excessive force? 2. Did the Ninth Circuit depart from this Court’s decision in Kisela v. Hughes, ___ U.S. ___, 138 S. Ct. 1148 (2018) (per curiam) and numerous other cases by denying qualified immunity even though two judges concluded the use of force was reasonable, and notwithstanding the absence of clearly established law imposing liability under circumstances closely analogous to those confronting petitioner?
Case path: United States Court of Appeals for the Ninth Circuit / Decision released Oct 18, 2021
Area: Decided Supreme Court case

Decision

Decision recordOct 18, 2021

What the Court decided

Rivas-Villegas could not be sued for damages on this excessive-force claim because the law had not clearly established that his actions were unconstitutional.

Impact

The decision protects the officer from this damages claim because earlier cases had not clearly established that the conduct was unconstitutional. It affects officers and people alleging excessive force during arrests involving a possible weapon.

Not official Court text.

Opinion documents

Opinion

Briefing

What it's about

The Supreme Court said Officer Pedro Rivas-Villegas was entitled to qualified immunity (protection from damages lawsuits in some cases). The case involved an excessive-force claim after he briefly put his knee on the back of a suspect with a knife in his pocket while officers disarmed and handcuffed him.

Vote

The Court decided that Rivas-Villegas was entitled to qualified immunity; the vote and opinion lineup are not stated.

Impact

The decision protects the officer from this damages claim because earlier cases had not clearly established that the conduct was unconstitutional. It affects officers and people alleging excessive force during arrests involving a possible weapon.

What's next

The Supreme Court has finished this docket action. The qualified-immunity decision applies to the claim against Rivas-Villegas.

What did the Supreme Court rule in Rivas-Villegas v. Cortesluna?

The Court said Officer Rivas-Villegas was entitled to qualified immunity from the excessive-force damages claim.

Who is affected by the Rivas-Villegas decision?

Police officers facing force-related damages claims and people alleging excessive force may be affected. The result turns on whether prior law clearly covered similar conduct.

What happens next in Rivas-Villegas v. Cortesluna?

The Supreme Court has completed the case. Its qualified-immunity decision resolves the claim against Rivas-Villegas.

Timing

Decided October 18, 2021

The Court released its decision on October 18, 2021 without hearing oral argument.

Argument and decision days

Documents

Opinions

Opinion

Key filings

Petition

Briefs on file: 3View on supremecourt.gov

View full docket on supremecourt.gov

Activity

Docket activity3

AI analysis generated: Case Briefing
Sep 3, 2026 | Generated
Opinion added: Opinion
Oct 18, 2021 | Court records
Brief added: Petition
Apr 30, 2021 | Court records

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Grounding

Grounding: Primary materials plus reporting.
Note: Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
Checked: Sep 3, 2026
Method: Methodology

Primary materials8

Context reporting4