Fourth Circuit revives excessive-force case over 2021 Chesterfield police K-9 bite
A federal appellate opinion recounts Richard Harrold’s allegations that Chesterfield County Police K-9 Kona inflicted severe bite injuries during a December 26, 2021 dealership arrest; the court vacated a qualified-immunity dismissal without deciding ultimate liability.
Incident summary
A published Fourth Circuit opinion recounts allegations arising from a December 26, 2021 arrest at a Chesterfield County car dealership. Richard Harrold alleged that Officer Lewis Hagen deployed leashed police K-9 Kona after officers found Harrold in an upstairs storage room and that the dog caused severe bite injuries before he was transported to a hospital. The appellate court did not decide the ultimate factual merits or liability; it vacated a qualified-immunity dismissal and allowed the federal excessive-force claim to continue.
On April 28, 2026, a divided Fourth Circuit panel vacated the district court’s dismissal of Harrold’s federal excessive-force claim and remanded for further proceedings. The majority held that the complaint alleged violation of a clearly established Fourth Amendment right. Because the case was reviewed at the motion-to-dismiss stage, the court accepted well-pleaded allegations for that analysis; the ruling is not a trial verdict that every alleged fact occurred or that Officer Hagen is ultimately liable.
Video, reporting and source material
BiteDB embeds media only when a source-hosted player is suitable for embedding. News photographs and footage remain with their publishers unless reuse rights are clear.
Primary record used by BiteDB
The Fourth Circuit’s April 28, 2026 published opinion states that Harrold’s complaint arose from the December 26, 2021 arrest by Chesterfield County Police Officer Lewis Hagen and K-9 Kona. The opinion recounts the complaint’s allegations of deep dog bites, substantial blood loss, emergency bleeding-control treatment, destruction of Harrold’s prosthetic leg, and transport to Chippenham Hospital. The majority held that, accepting the properly pleaded allegations at the Rule 12(b)(6) stage, the asserted Fourth Amendment right was clearly established and vacated the dismissal.
Open original source ↗Additional sources
- Fourth Circuit — opinion announcement for Harrold v. Hagen — Primary federal court docket/decision announcement · 2026-04-28
- Justia — Harrold v. Hagen opinion text and procedural summary — Secondary court-opinion mirror / readable corroboration · 2026-04-28
What BiteDB does not infer
Breed is recorded only at the provenance level shown above. Missing injury details, dog history, ownership facts or circumstances remain unknown unless a reliable source establishes them. This record may be updated as police, animal-control, medical, court or follow-up reporting becomes available.