Law School Case Brief
Scott v. Harris - 550 U.S. 372, 127 S. Ct. 1769 (2007)
At the summary judgment stage, facts must be viewed in the light most favorable to the nonmoving party only if there is a "genuine" dispute as to those facts. Fed. R. Civ. P. 56(c). Where the record taken as a whole could not lead a rational trier of fact to find for the nonmoving party, there is no genuine issue for trial. The mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment. When opposing parties tell two different stories, one of which is blatantly contradicted by the record, a court should not adopt that version of the facts for purposes of ruling on a motion for summary judgment.
Petitioner Deputy Timothy Scott terminated a high-speed pursuit of respondent's car by applying his push bumper to the rear of the vehicle, causing it to leave the road and crash. Respondent was rendered quadriplegic. He filed suit under 42 U.S.C. § 1983 alleging, inter alia, the use of excessive force resulting in an unreasonable seizure under the Fourth Amendment. The district court denied Scott's summary judgment motion, which was based on qualified immunity. The court of appeals affirmed on interlocutory appeal, concluding that Scott's actions could constitute deadly force which would violate respondent's constitutional right to be free from excessive force during a seizure; and that a reasonable jury could so find.
Was summary judgment properly denied despite the deputy’s qualified immunity?
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.
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