Tolan v. Cotton

Brief Fact Summary.

During the early morning hours, Defendant – a police officer – fired three bullets at Plaintiff who was mistakenly accused of exiting a stolen car. One of the bullets punctured Plaintiff’s right lung. Plaintiff was unarmed on his parents’ front porch about 15 to 20 feet away from the officer. Plaintiff appeared to be shot after he reacted to the way Defendant treated his mother. There were differing versions as to how the plaintiff reacted. The Fifth Circuit affirmed the lower court’s decision, reasoning that Defendant was entitled to qualified immunity because he did not violate any clearly established right.

Synopsis of Rule of Law.

A court may grant a motion for summary judgment only when the evidence, viewed in the light most favorable to the non-movant, establishes that the movant is entitled to judgment as a matter of law.

Facts.

At approximately 2:00 in the morning, Officer Edwards noticed a vehicle turning onto a residential street and parking in front of a house. Edwards mistakenly believed the vehicle was stolen. Plaintiffs exited the car. Edwards accused them of stealing the car, and Plaintiff Tolan stated that it was his car. Plaintiff Tolan’s parents came outside and reiterated that the vehicle belonged to Plaintiff Tolan, who lived with them. Defendant arrived on the scene and ordered Plaintiff Tolan’s mother to stand against the garage door. Defendant escorted Plaintiff Tolan’s mother and may have pushed her up against the garage door. Plaintiff Tolan testified that he reacted to this and rose to his knees. Edwards and Defendant testified that Tolan rose to his feet. All parties agreed that Tolan exclaimed, “Get your fucking hands off my mom.” Defendant then shot Plaintiff Tolan, piercing his liver and collapsing his right lung. Plaintiff Tolan survived but suffered a life-altering injury. Plaintiffs sued Defendant under 42 U.S.C. § 1983, alleging that the use of excessive force violated the Fourth Amendment. After discovery, Defendant moved for summary judgment. The trial court granted summary judgment. Plaintiff Tolan appealed to the United States Court of Appeals for the Fifth Circuit, which affirmed. Plaintiff Tolan then petitioned the United States Supreme Court for review.

Issue.

May a court grant a motion for summary judgment when the evidence was not viewed in the light most favorable to the non-movant?

Held.

No. The Supreme Court vacated the judgment of the Fifth Circuit, holding that the Fifth Circuit failed to view the evidence at summary judgment in the light most favorable to plaintiff with respect to the central facts of the case.

Discussion.

A court may grant a motion for summary judgment only when the evidence, viewed in the light most favorable to the non-movant, establishes that the movant is entitled to judgment as a matter of law. For the purposes of a motion for summary judgment, the evidence of the non-movant is to be believed, and all justifiable inferences are to be drawn in his favor. Anderson v. Liberty Lobby, Inc., 477 U.S. 242 255 (1986). If there are genuine factual disputes, they should generally be resolved by juries. Here, the trial court and the court of appeals failed to view the evidence in the light most favorable to Plaintiffs, the non-movant. The factual conclusions drawn by the courts below are contradicted by evidence presented by Plaintiffs. The parties had genuine factual disputes about: (1) the lighting, (2) the demeanor of Plaintiff Tolan’s mother, (3) whether Plaintiff Tolan shouted threats at the officers, and (4) Plaintiff Tolan’s positioning during the shooting. In each case, Plaintiffs presented evidence that could be interpreted to support his claim. The courts below improperly credited Defendant’s proof over Plaintiffs’ proof, resolving the disputed issues in favor of the movant. These factual disputes were not properly decided in a motion for summary judgment. Therefore, the judgment of the trial court was reversed.