Not a Lexis Advance subscriber? Try it out for free.

Saucier v. Katz

Supreme Court of the United States

March 20, 2001, Argued ; June 18, 2001, Decided

No. 99-1977

Case Summary

Procedural Posture

Respondent protestor sued petitioner officer, alleging that the officer violated the protestor's Fourth Amendment rights by using excessive force to arrest him. The United States Court of Appeals for the Ninth Circuit affirmed the denial of qualified immunity to the officer, determining that summary judgment based on qualified immunity was inappropriate. The officer's petition for writ of certiorari was granted.

Overview

At about the time the Vice President of the United States began speaking at a public gathering, respondent protestor raised a banner and walked toward the speakers' platform. Petitioner officer arrested the protestor and shoved him into a van. The protestor sued the officer, alleging excessive force. The district court denied the officer's summary judgment motion on the grounds of qualified immunity. The appellate court affirmed, finding that qualified immunity was duplicative in an excessive force case. On certiorari, the Supreme Court reversed because the inquiries for qualified immunity and excessive force remained distinct and the officer was entitled to qualified immunity. The initial inquiry should have been whether the facts alleged showed the officer's conduct violated a constitutional right. The next question should have been whether the right was clearly established in the context of the case. In the circumstances presented to the officer, which included the duty to protect the safety and security of the Vice President, there was no clearly established rule prohibiting the officer from acting as he did.

Outcome

Judgment denying qualified immunity was reversed.

LexisNexis® Headnotes

 

 

Civil Rights Law > ... > Immunity From Liability > Local Officials > Customs & Policies

HN1  Local Officials, Customs & Policies

In a suit against an officer for an alleged violation of a constitutional right, the requisites of a qualified immunity defense must be considered in proper sequence. Where the defendant seeks qualified immunity, a ruling on that issue should be made early in the proceedings so that the costs and expenses of trial are avoided where the defense is dispositive. Qualified immunity is an entitlement not to stand trial or face the other burdens of litigation. The privilege is an immunity from suit rather than a mere defense to liability; and like an absolute immunity, it is effectively lost if a case is erroneously permitted to go to trial. As a result, the importance of resolving immunity questions at the earliest possible stage in litigation is stressed.

 

Civil Rights Law > ... > Immunity From Liability > Local Officials > Customs & Policies

HN2  Local Officials, Customs & Policies

A court required to rule upon the qualified immunity issue must consider this 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? This must be the initial inquiry.

 

Civil Rights Law > ... > Immunity From Liability > Local Officials > Customs & Policies

HN3  Local Officials, Customs & Policies

If no constitutional right would have been violated were the allegations established, there is no necessity for further inquiries concerning qualified immunity. On the other hand, if a violation could be made out on a favorable view of the parties' submissions, the next, sequential step is to ask whether the right was clearly established. This inquiry must be undertaken in light of the specific context of the case, not as a broad general proposition; and it too serves to advance understanding of the law and to allow officers to avoid the burden of trial if qualified immunity is applicable.

Access the full text caseNot a Lexis Advance subscriber? Try it out for free.

533 U.S. 194 ; 121 S. Ct. 2151 ; 150 L. Ed. 2d 272 ; 2001 U.S. LEXIS 4664 ; 69 U.S.L.W. 4481; 2001 Cal. Daily Op. Service 5000; 2001 Daily Journal DAR 6137; 2001 Colo. J. C.A.R. 3134; 14 Fla. L. Weekly Fed. S 361

DONALD SAUCIER v. ELLIOT M. KATZ AND IN DEFENSE OF ANIMALS

Prior History:  [1]  ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.

Disposition: 194 F.3d 962, reversed and remanded.