Facts of the case
After a police officer attempted to pull him over for speeding, Victor Harris fled in his vehicle, initiating a high-speed car chase. Attempting to end the chase, Deputy Timothy Scott rammed Harris’s vehicle with his police cruiser. Harris crashed and was rendered a quadriplegic. Harris sued Scott in federal District Court, alleging that Scott had violated his Fourth Amendment rights by using excessive force. Scott claimed qualified immunity as a government official acting in his official capacity, but the District Court rejected the claim. The U.S. Court of Appeals for the Eleventh Circuit affirmed.In order to show that a government official is not entitled to qualified immunity, a plaintiff is required to prove that the official violated a clearly established constitutional right. The Eleventh Circuit ruled that Scott’s actions constituted an unreasonable seizure in violation of the Fourth Amendment. Because there was no imminent threat – Harris remained in control of his vehicle and the roads were relatively empty – Scott’s use of deadly force was unconstitutional. Although no Appellate Court had ruled on the specific question of the use of deadly force in a high-speed chase, the Eleventh Circuit ruled that the limits on deadly force were clearly established.
Why is the case important?
A police officer in pursuit hit the back of motorist’s vehicle to stop him from hurting innocent bystanders.
Whether the summary judgment standard of viewing the facts in light most favorably of the non-moving party, requires the court to put more weight in testimony than video tape evidence to the contrary. Also, whether the police officer actions were reasonable under the fourth amendment is the second issue.
NO. Upon a Summary Judgment motion it is the moving party’s burden to show there is no genuine issue of material fact. Only then does the burden shift to the non-moving party to state otherwise. However, here the non-moving party (motorist) only gave testimony that he was driving perfectly. The police officer had a video tape of the entire tape showing seriously reckless driving. The court found that the record of all evidence could not lead a rationale trier of the fact to find for the non-moving party. Therefore there was no genuine issue of material fact. The court found the lower court was wrong in only relying on that testimony. The central issue for trial is whether motorist drove in such a way to engage human life. Here since the motorist story was completely discredited by the video tape and he had no other evidence, no reasonable jury would find for the motorist. There mere existence of an alleged fact is not enough.
In resolving questions of qualified immunity, courts are required to resolve a threshold question: Taken in the light most favorable to the party asserting the injury, do the facts alleged show the officer’s conduct violated a constitutional right? The videotape capturing the events in question quite clearly contradicted the version of the story told by the driver and adopted by the court of appeals. The court of appeals should have viewed the facts in the light depicted by the videotape. The deputy did not contest that his decision to terminate the car chase by ramming his bumper into the driver’s vehicle constituted a seizure.A police officer’s attempt to terminate a dangerous high-speed car chase that threatened the lives of innocent bystanders did not violate the Fourth Amendment, even when it placed the fleeing motorist at risk of serious injury or death. The car chase that the driver initiated posed a substantial and immediate risk of serious physical injury to others. The deputy’s attempt to terminate the chase by forcing the driver off the road was reasonable, and the deputy was entitled to summary judgment.
- Advocates: Philip W. Savrin for the petitioner Gregory G. Garre Deputy Solicitor General, Department of Justice, for the United States as amicus curiae, supporting the petitioner Craig T. Jones for the respondent
- Petitioner: Timothy Scott
- Respondent: Victor Harris
- DECIDED BY:Roberts Court
- Location: –
|Citation:||550 US 372 (2007)|
|Granted:||Oct 27, 2006|
|Argued:||Feb 26, 2007|
|Decided:||Apr 30, 2007|