RYAN FRANKE v. KENNY JANES, individually - Articles

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RYAN FRANKE v. KENNY JANES, individually

Posted by: Azya Thornton on Mar 2, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Rob Astorino, Jr., STEIN WHATLEY ASTORINO, PLLC, Louisville, Kentucky, for Appellant.

Attorneys 2: ARGUED: Mark A. Osbourn, BUSH & OSBOURN, PLLC, Louisville, Kentucky, for Appellee.

Attorneys 3: ON BRIEF: Rob Astorino, Jr., STEIN WHATLEY ASTORINO, PLLC, Louisville, Kentucky, for Appellant.

Attorneys 4: ON BRIEF: Mark A. Osbourn, BUSH & OSBOURN, PLLC, Louisville, Kentucky, for Appellee.

Judge(s): MOORE, BUSH, and DAVIS, Circuit Judges

Court Appealed: United States District Court for the Western District of Kentucky at Louisville

DAVIS, Circuit Judge. In March 2022, police handcuffed and detained Ryan Franke outside a local recreational center on suspicion of domestic violence against his ex-wife. After handcuffing Franke, Officer Kenny Janes escorted him toward a police vehicle. During the walk to the vehicle, Franke yelled out to nearby family members, which led Janes to apply pain compliance techniques to keep Franke moving. Later, Janes allegedly twisted Franke’s wrist, causing injury. Franke brought this civil rights action, claiming that Janes used excessive force. The district court found that Janes is protected by qualified immunity and granted him summary judgment on that basis. Because there is a genuine dispute of material fact concerning the need for the amount of force applied, we AFFIRM IN PART, REVERSE IN PART, and REMAND for further proceedings.

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