Scott v. Harris

Brief Fact Summary.

Respondent sued Petitioner for excessive force in violation of the Fourth Amendment. Petitioner moved for summary judgment arguing qualified immunity barred the lawsuit.

Synopsis of Rule of Law.

When considering a motion for summary judgment, a court must view the facts in the light most favorable to the nonmoving party, unless there is no genuine dispute regarding the facts.

Facts.

During a highspeed chase, Deputy Timothy Scott (Petitioner) used his car to hit the rear of Harris’s car (Respondent), causing the car to crash and rendering Respondent quadriplegic. Respondent sued Petitioner, arguing he had used excessive force in violation of the Fourth Amendment. Petitioner moved for summary judgment, arguing the case was barred by qualified immunity.

Issue.

Did the lower courts properly deny summary judgment, on the basis of disputed facts regarding the reasonableness of Petitioner’s actions?

Held.

No, based on the video evidence there was no dispute as to the reasonableness of Petitioner’s actions. The lower court’s decision is reversed.

Dissent.

Justice Stevens

Justice Stevens agued that the video evidence was not as persuasive as the Court tried to make it out to be and that the lower courts were proper to want to send the case to trial for a jury to decide whether the Petitioner acted with deadly force.

Concurrence.

Justice Ginsburg

Justice Ginsburg agreed with the Court’s opinion, but emphasized that the decision was fact specific and did not create a hardline rule about the use of reasonable force during car chases.

Justice Breyer

Justice Breyer agreed with the Court’s opinion, emphasizing the importance of the videotape in demonstrating that Petitioner acted reasonably. But Justice Breyer agreed with Justice Ginsburg that the Court should not make a rule regarding this use of force because it was fact specific.

Discussion.

The Court determined that the facts did not need to be viewed in the light most favorable to Respondent, because the video evidence showing the events were enough to demonstrate that Petitioner did not violate the Fourth Amendment. The Court determined that the video showed Respondent driving recklessly and that Petitioner had acted reasonably to stop him, regardless of whether or not he had used deadly force.