Can a police officer be held personally liable for failing to intervene to stop excessive force?

14. We make one important qualification: We consider the issue of failure-to-intervene liability solely in conjunction with plaintiffs' conspiracy allegations. Limiting ourselves to the issues raised by plaintiffs on this appeal, we do not decide whether these defendants (or police officers in general) may be held directly and individually liable under section 1983 for passively observing the use of constitutionally excessive force that could have been prevented. (See, e.g., Ensley v. Soper (11th Cir. 1998) 142 F.3d 1402, 1408 [police officers may be held liable for failing to intervene to halt excessive force, although "we see no evidence in the record that might show that [defendant] observed his fellow officers' alleged abuse of [plaintiff] or that he had opportunity to intervene"].)

14. We make one important qualification: We consider the issue of failure-to-intervene liability solely in conjunction with plaintiffs' conspiracy allegations. Limiting ourselves to the issues raised by plaintiffs on this appeal, we do not decide whether these defendants (or police officers in general) may be held directly and individually liable under section 1983 for passively observing the use of constitutionally excessive force that could have been prevented. (See, e.g., Ensley v. Soper (11th Cir. 1998) 142 F.3d 1402, 1408 [police officers may be held liable for failing to intervene to halt excessive force, although "we see no evidence in the record that might show that [defendant] observed his fellow officers' alleged abuse of [plaintiff] or that he had opportunity to intervene"].)