Mullenix v. Luna

PETITIONER: Chadrin Lee Mullenix
RESPONDENT: Beatrice Luna, individually and as representative of the estate of Israel Leija, Jr., et al.
LOCATION: I-27 and Cemetery Road Overpass

DOCKET NO.: 14-1143
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 577 US (2015)
GRANTED: Nov 09, 2015
DECIDED: Nov 09, 2015

Facts of the case

On March 23, 2010, a police officer approached Israel Leija, Jr. at a drive-in restaurant with a warrant for his arrest. Leija proceeded to lead the police on a high-speed chase on the interstate while periodically calling the police dispatcher, saying that he had a gun and threatening to shoot the officers chasing him. The officers continued their pursuit, and other officers deployed spike strips. Trooper Chadrin Lee Mullenix, upon learning that other spike strips were set up, decided to pursue the alternate tactic of shooting at Leija’s car in order to stop it. Although he had not received training on this maneuver, he informed one of the officers in pursuit of his plan and radioed his supervisor for permission. Before receiving a response, Mullenix got in position on an overpass. Witnesses testified that Mullenix could hear his supervisor respond to say that he should “stand by” and “see if the spikes work first.” When Leija’s car approached, Mullenix fired six shots. The car struck the spike strips, hit the median, and rolled several times. It was later determined that Leija died as a result of Mullenix’ shots, four of which struck his body and none of which struck the car’s radiator, hood, or engine block.

The respondents sued Mullenix under 42 U.S.C. §1983 and argued that Mullenix had violated Leija’s Fourth Amendment rights by using excessive force against him. Mullenix moved for summary judgment and argued that he was entitled to qualified immunity. The district court denied the motion and held that there were genuine questions of fact regarding whether Mullenix acted as a reasonable officer would have under similar circumstances. The U.S. Court of Appeals for the Fifth Circuit affirmed and subsequently denied Mullenix’s petition for a rehearing.

Question

Did the district court and the U.S. Court of Appeals for the Fifth Circuit err in determining that Chadrin Lee Mullenix was not entitled to qualified immunity?