A federal judge has ruled against the city of Buhl in a case where the city’s police chief was accused of illegally entering a private home without a warrant and using excessive force.
A traffic stop in late December 2023 escalated into three officers forcing their way into a private home and tasing Elisha “Eli” Johnson twice, as his wife and child watched. Police said Johnson moved his car a short distance into his driveway during the traffic stop and went inside his home, ignoring their commands.
While talking with Johnson at his doorway, Buhl Police Chief Jeremy Engbaum blocked the door from shutting with his foot, and according to court documents, ultimately ordered two other officers on scene to help him force their way inside. Johnson was pulled from his home and tased twice; officers said he resisted arrest.
District Chief Magistrate Judge Raymond Patricco ruled this week that these actions violated Johnson and his family’s Fourth Amendment protections. But the question of whether Engbaum used excessive force during the arrest will be answered at a future jury trial.
“The Court has carefully reviewed the [body cam] footage and believes a jury could find in either party’s favor on this issue,” Patricco wrote, calling the body cam footage of the incident “quick, chaotic and confusing.”
Patricco’s ruling allowed Engbaum some qualified immunity protections, dismissing claims made against the police chief in a personal capacity, but noted that immunity was not necessarily permanent.
“The Court will allow both excessive force claims to proceed to trial and will reconsider Defendant Engbaum’s qualified immunity defense after the jury has made factual findings about Johnson’s resistance during the arrest,” he wrote.
Court filings show a settlement conference is planned for the potential determination of damages owed to Johnson and his family, but a jury could determine damages if a settlement is not reached. A trial date for the remaining issues has not been set.
Note: The original audio report for this story, which aired on Boise State Public Radio the morning of Friday, September 26, 2025, included a mispronunciation of Judge Raymond Patricco’s name. It has been updated.
