Law School Case Brief
Cty. of Sacramento v. Lewis - 523 U.S. 833, 118 S. Ct. 1708 (1998)
A police officer deciding whether to give chase must balance on one hand the need to stop a suspect and show that flight from the law is no way to freedom, and, on the other, the high-speed threat to everyone within stopping range, be they suspects, their passengers, other drivers, or bystanders. High-speed chases with no intent to harm suspects physically or to worsen their legal plight do not give rise to liability under U.S. Const. amend. XIV.
After James Smith, a county sheriff's deputy, responded to a call along with another officer, Murray Stapp, Stapp returned to his patrol car and saw a motorcycle approaching at high speed, driven by Brian Willard, and carrying Philip Lewis, plaintiffs' decedent, as a passenger. Stapp turned on his rotating lights, yelled for the motorcycle to stop, and pulled his car closer to Smith's in an attempt to pen the motorcycle in, but Willard maneuvered between the two cars and sped off. Smith immediately switched on his own emergency lights and siren and began high-speed pursuit. The chase ended after the cycle tipped over. Smith slammed on his brakes, but his car skidded into Lewis, causing massive injuries and death. Plaintiffs, Lewis's parents, brought this action against defendants, Sacramento County, the Sacramento County Sheriff's Department and Deputy Smith, under 42 U.S.C. § 1983, alleging a deprivation of Lewis's Fourteenth Amendment substantive due process right to life. The District Court granted summary judgment for defendant Smith, but the Ninth Circuit reversed, holding, inter alia, that the appropriate degree of fault for substantive due process liability for high-speed police pursuits was deliberate indifference to, or reckless disregard for, a person's right to life and personal security. Defendants sought further review in the United States Supreme Court.
Did a deputy sheriff violate a decedent's substantive due process by causing his death through reckless indifference to life when the deputy participated in a high-speed automobile chase aimed at apprehending a suspected offender?
The Court held that the deputy did not violate the Fourteenth Amendment’s guarantee of substantive due process by causing death through deliberate or reckless indifference to life in a high-speed automobile chase aimed at apprehending a suspected offender. According to the Court, high-speed police chases with no intent to harm suspects physically or to worsen their legal plight did not give rise to liability under the Fourteenth Amendment, redressable by an action under section 1983. The Court noted that it was suspect’s outrageous behavior that prompted the deputy's response as a law enforcement officer. The Court concluded that deputy was not liable because there was no improper or malicious motive in following the motorcycle in a high-speed chase.
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