The case was dismissed with a summary judgement, which is one of the earliest points a case can be dismissed. Arguing that the action was unreasonable is highly

The case was dismissed with a summary judgement, which is one of the earliest points a case can be dismissed. Arguing that the action was unreasonable is highly fact specific, and so cannot be done in summary judgement. In contrast, arguing that no seizure occured requires to finding of fact, because there was no dispute of any relevent fact, and so is done first.