The Third Circuit in Jutrowski v. Township of Riverdale, a § 1983 suit against local police officers and state troopers, found a legal theory to pierce the alleged “blue wall of silence” in a case where the plaintiff could not identify the particular officer who kicked him on the face  when he was pinned to the ground. None of the dashboard cameras captured the incident, and the officers all testified that they had not kicked the plaintiff, nor did they know who did.

Excessive force claims under § 1983 require proof of personal involvement. Liability may not be based upon membership in a group in which other members were guilty of abuses. The lack of direct proof and the denial by all the officers precluded § 1983 responsibility.