County of Sacramento v. Lewis

Brief Fact Summary. Lewis (Respondent) was a passenger on a motorcycle that was chased by police. When the motorcycle stopped, the police cruiser did not. Respondent was hit and killed at the scene.

Synopsis of Rule of Law. Government conduct that “shocks the conscience” and violates the “decencies of civilized conduct” also violates the Fourteenth Amendment. In emergency situations, the government is afforded greater leeway.

Facts. A police officer was responding to a fight when Respondent and another failed to adhere to the police demand to stop. Instead of stopping, they maneuvered between police cars and sped off. The officer chose to pursue Respondent through a residential neighborhood at speeds of up to 100 mph. While trying to make a sharp left turn, the motorcycle slid and both driver and passenger were thrown. The cruiser avoided hitting the driver, but hit Respondent and threw him 70 feet. He was pronounced dead at the scene.

Issue. Did the officer violate substantive due process when he caused the death of Respondent during a high-speed chase?

Held. No. The police officer did not intend to harm or worsen the plight of Respondent.

Discussion. The police officer was doing his job and using his best judgment at the time of the pursuit. He did not intend to kill Respondent or harm him in any way. If he had, then the conduct would be “shocking” and held to violate the United States Constitution.