A federal appeals court is reviewing the dismissal of a lawsuit filed by a San Antonio woman who was knocked unconscious after a police officer shoved her while she was handcuffed and pregnant. The officer claims she was fleeing; her attorneys say what happened was excessive, unconstitutional, and should have been decided by a jury.

The incident occurred on the night of October 2, 2022, in the parking lot of a 7-Eleven on South Zarzamora Street. Samantha Lee-Ann Sealey, who was three months pregnant at the time, had just been handcuffed by San Antonio Police Officer Arturo Mancias on an outstanding drug warrant.

What happened next is now at the center of a legal battle — one that involves contested video footage, constitutional questions about police force, and the dismissal of a civil rights case before any discovery could take place.

🎥 Full bodycam video of the incident is available below. The footage shows Sealey, who is handcuffed, falling face-first to the pavement and lying motionless. Some viewers may find the video graphic. Viewer discretion is advised.

A 6-Second Sequence With Long-Term Consequences

After a brief verbal exchange in which Sealey asked about the warrant and admitted to having an empty syringe in her bra, the video shows her suddenly flee — still handcuffed — across the parking lot. Officer Mancias gave chase and caught up to her within seconds.

The footage does not clearly show the moment of contact. Sealey’s body rotates and then collapses forward, sliding across the concrete.

She appears unconscious within seconds. Blood can be seen pooling from her head.

Mancias radioed for emergency medical assistance, telling dispatch, “She hit her head pretty good on the concrete.” He did not report any use of force in that transmission. According to the lawsuit, Sealey was placed in a medically induced coma and later suffered a miscarriage.

Lawsuit Dismissed Before Trial

In April 2024, Sealey filed a lawsuit in federal court under 42 U.S.C. § 1983, alleging that Officer Mancias used unconstitutionally excessive force and that the City of San Antonio failed to properly train officers on how to handle takedowns of handcuffed individuals.

The case was dismissed in November by U.S. District Judge Xavier Rodriguez, who concluded that the video was too ambiguous to clearly prove that Mancias had pushed her — and that the officer’s actions did not violate “clearly established law” at the time of the incident.

The judge acknowledged that the body-worn camera did not show Mancias’s hands at the moment Sealey fell, but he held that the ambiguity did not overcome qualified immunity, a legal doctrine that shields government officials from civil liability unless their conduct clearly violates constitutional rights.

“It is impossible to determine with certainty where Officer Mancias’ arms were while he chased her,” the judge wrote. “The video does not clearly show whether [Sealey] may have fallen on her own, whether she may have fallen after Officer Marcias tried to pull her back, or whether she fell due to Officer Mancias pushing her, as she alleges.”

Appeal: “This Was Not a Trip — This Was a Shove”

Sealey’s attorneys have appealed to the U.S. Court of Appeals for the Fifth Circuit, arguing that the case should not have been dismissed before discovery or a jury trial.

The appeal calls the officer’s actions “extreme and unjustified,” and asserts that pushing a handcuffed, pregnant woman face-first onto concrete constitutes excessive and potentially deadly force, regardless of whether she was attempting to flee.

Sealey posed no threat, the brief argues. She was handcuffed, unarmed, and not suspected of violence. The use of force in this case created a foreseeable risk of serious harm and violated clearly established law.

The filing cites several Fifth Circuit precedents where officers were held liable for force that posed a substantial risk of trauma or death, including Timpa v. Dillard, Gutierrez v. San Antonio, and Aguirre v. City of San Antonio.

Defense: She Was Fleeing, and the Video Doesn’t Show a Push

Attorneys for Officer Mancias argue that his actions were lawful and measured. According to their brief, Sealey fled without warning, sprinting toward a darkened area near the edge of the parking lot. The officer attempted to stop her — but, they claim, there’s no evidence he used excessive force.

“She fled while handcuffed, had not been searched, and was headed into darkness and toward a nearby roadway,” the officer’s brief states. Stopping a fleeing arrestee under these conditions does not violate clearly established law.

They further argue that no prior case puts officers on notice that stopping a handcuffed arrestee in flight — without visible use of weapons — would amount to unconstitutional conduct.

Disputed Evidence and an Unseen Witness

Sealey’s legal team attempted to supplement the trial court record with the video-recorded statement of a witness, a friend named Santos Rodriguez, who reportedly observed the incident and stated that the officer did push Sealey. According to the appellate brief, the district court never ruled on the admissibility of that evidence, raising further concerns about the fairness of the dismissal.

Additionally, attorneys argue that footage from other officers’ body-worn or dash cameras was never released, leaving gaps in the visual record of the incident.

Qualified Immunity and the Question of Jury Review

The case touches on broader national debates about qualified immunity — a legal doctrine that often shields law enforcement officers from liability unless their actions violate “clearly established” constitutional law.

Critics argue the doctrine too often blocks excessive force cases from reaching juries, even when the facts are disputed or the injuries are severe. Supporters say it protects officers from lawsuits for split-second decisions made in uncertain circumstances.

In this case, the district court concluded that the ambiguity in the video and the lack of clearly established precedent justified dismissal at the pleading stage — without discovery or trial.

The Fifth Circuit Court of Appeals has not yet scheduled oral argument.

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