Scott v. Harris

Brief Fact Summary.

Police officer causes man involved in a high speed chase to become a quadraplegic. The police officer moves for summary judgement based on qualified immunity which is denied by the district court and affirmed by the court of appeals.

Synopsis of Rule of Law.

(1) In deciding a motion for summary judgment, all facts are viewed in the light most favorable to the non-moving party unless no reasonable jury would be able to accept that version of the facts and (2) the use of deadly force to terminate a high-speed vehicle chase does not violate the Fourth Amendment.

Facts.

Defendant Scott observed Plaintiff Harris speeding. When Defendant Scott attempted to stop Plaintiff Harris, Harris fled. The incident turned into a high speed chase that was brought to an end when Defendant Scott—after receiving the okay from his supervisor to perform a maneuver to Plaintiff Harris’ car that would cause it to spin to a stop—misfired, causing Plaintiff Harris’ car to hit a tree. As a result of the crash Plaintiff Harris became a quadriplegic. The entire chase was caught on Defendant’s dash cam. Plaintiff Harris sued Defendant Scott for violating his Fourth Amendment right protecting him from unreasonable seizure. Both parties agreed that Defendant Scott’s actions were a seizure under the Fourth Amendment. Defendant Scott moved for summary judgement based on qualified immunity. The district court denied his motion, holding that there were disagreements as to material facts. The United States Court of Appeals for the Eleventh Circuit affirmed. Defendant Scott then appealed to the United States Supreme Court which granted certiorari.

Issue.

(1) In deciding a motion for summary judgement must a court view all facts in the light most favorable to the non-moving party even if the non-moving party’s version of the facts are contradicted by evidence?

(2) Does the use of deadly force to stop a high-speed chase violate the Fourth Amendment.

Held.

(1) No, in a motion for summary judgement the court views all of the facts in the light most favorable to the non-moving party except when the non-moving party’s version of the facts is directly contradicted by evidence. There is no dispute of material facts and the court of appeals decision is reversed.

(2) No, the use of deadly force to stop a high-speed chase does not violate the Fourth Amendment. The decision of the court of appeals is reversed.

Discussion.

1. When there is a set of facts and one view is directly contradicted by evidence, then there is no genuine dispute of material fact.
2. Both the district court and the court of appeals believe that Plaintiff Harris was not a danger to bystanders, but the video of the chase demands a different conclusion.
3. The video evidence is so compelling that no jury could accept Plaintiff Harris’ version of events.
4. Therefore, there is no dispute of material facts and the court of appeals decision is reversed.
5. The use of excessive force to carry out a seizure does not violate the Fourth Amendment if the force is objectively reasonable.
6. Plaintiff Harris incorrectly applies the Court’s test from Garner. Instead, the question here is whether the risk posed to Plaintiff Harris by Defendant Scott’s actions, not the risk to the public arising from Plaintiff Harris’s attempted escape.
7. Plaintiff Scott’s use of force to stop Plaintiff Harris from injuring innocent members of the general public was reasonable because had they not stopped him, he probably would have continued to drive recklessly and continue endangering people.
8. The court now holds that the use of force to end a high speed chase that presents a threat to public safety, even when the use of force poses serious risk to the fleeing suspect, does not violate the Fourth Amendment. The decision of the court of appeals is reversed.