County of Sacramento v. Lewis
Supreme Court of the United States
December 9, 1997, Argued ; May 26, 1998, Decided
[***1051] [**1711] [*836] JUSTICE SOUTER delivered the opinion of the Court.
The issue in this case is whether a police officer violates the Fourteenth Amendment's guarantee of substantive due process by causing death through deliberate or reckless [****7] indifference to life in a high-speed automobile chase aimed at apprehending a suspected offender. We answer no, and hold that in such circumstances only a purpose to cause harm unrelated to the legitimate object of arrest will satisfy the element of arbitrary [**1712] conduct shocking to the conscience, necessary for a due process violation.
On May 22, 1990, at approximately 8:30 p.m., petitioner James Everett Smith, a Sacramento County sheriff's deputy, along with another officer, Murray Stapp, responded to a call to break up a fight. Upon returning to his patrol car, Stapp saw a motorcycle approaching at high speed. It was operated by 18-year-old Brian Willard and carried Philip Lewis, respondents' 16-year-old decedent, as a passenger. Neither boy had anything to do with the fight that prompted the call to the police.
Stapp turned on his overhead rotating lights, yelled to the boys to stop, and pulled his patrol car closer to Smith's, attempting to pen the motorcycle in. Instead of pulling over in response to Stapp's warning lights and commands, Willard [*837] slowly maneuvered the cycle between the two police cars and sped off. Smith immediately switched on his own emergency [***1052] lights and siren, [****8] made a quick turn, and began pursuit at high speed. For 75 seconds over a course of 1.3 miles in a residential neighborhood, the motorcycle wove in and out of oncoming traffic, forcing two cars and a bicycle to swerve off of the road. The motorcycle and patrol car reached speeds up to 100 miles an hour, with Smith following at a distance as short as 100 feet; at that speed, his car would have required 650 feet to stop.
The chase ended after the motorcycle tipped over as Willard tried a sharp left turn. By the time Smith slammed on his brakes, Willard was out of the way, but Lewis was not. The patrol car skidded into him at 40 miles an hour, propelling him some 70 feet down the road and inflicting massive injuries. Lewis was pronounced dead at the scene.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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523 U.S. 833 *; 118 S. Ct. 1708 **; 140 L. Ed. 2d 1043 ***; 1998 U.S. LEXIS 3404 ****; 66 U.S.L.W. 4407; 98 Cal. Daily Op. Service 3918; 98 Daily Journal DAR 5389; 1998 Colo. J. C.A.R. 2577; 11 Fla. L. Weekly Fed. S 555
COUNTY OF SACRAMENTO, ET AL. v. TERI LEWIS AND THOMAS LEWIS, PERSONAL REPRESENTATIVES OF THE ESTATE OF PHILIP LEWIS, DECEASED
Prior History: [****1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.
Disposition: 98 F.3d 434, reversed.
substantive due process, seizure, deliberate indifference, fourteenth amendment, reckless, shocking, pursuit, chase, circumstances, deprivation, qualified immunity, due process, Fourth Amendment, deliberate, high-speed, police pursuit, Heights, cases, due process right, shocks-the-conscience, conscience, executive action, police officer, fault, shocks the conscience, tort law, indifference, municipal, suspects, speed
Governments, State & Territorial Governments, Claims By & Against, Torts, Types of Damages, Property Damages, General Overview, Public Entity Liability, Liability, Constitutional Law, Fundamental Rights, Procedural Due Process, Substantive Due Process, Scope, Search & Seizure, Scope of Protection, Criminal Law & Procedure