Scott v. Harris

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Scott v. Harris
Seal of the United States Supreme Court.svg
Argued February 26, 2007
Decided April 30, 2007
Full case nameTimothy Scott v. Victor Harris
Docket no. 05-1631
Citations550 U.S. 372 ( more )
127 S. Ct. 1769; 167 L. Ed. 2d 686
Case history
PriorSummary judgment for defendant denied, sub nom., Harris v. Coweta County, No. 01–148, N.D. Ga., Sept. 23, 2003; aff'd, 433 F.3d 807 (11th Cir. 2005); cert. granted, 549 U.S. ___ (2006)
Holding
Because the car chase respondent initiated posed a substantial and immediate risk of serious physical injury to others, Scott's attempt to terminate the chase by forcing respondent off the road was reasonable, and Scott is entitled to summary judgment.
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens  · Antonin Scalia
Anthony Kennedy  · David Souter
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Case opinions
MajorityScalia, joined by Roberts, Kennedy, Souter, Thomas, Ginsburg, Breyer, Alito
ConcurrenceGinsburg
ConcurrenceBreyer
DissentStevens
Laws applied
U.S. Const. amend. IV; 42 U.S.C.   § 1983

Scott v. Harris, 550 U.S. 372 (2007), was a decision by the Supreme Court of the United States involving a lawsuit against a sheriff's deputy brought by a motorist who was paralyzed after the officer ran his eluding vehicle off the road during a high-speed car chase. [1] The driver contended that this action was an unreasonable seizure under the Fourth Amendment. The case also involved the question of whether a police officer's qualified immunity shielded him from suit under Section 1983. On April 30, 2007, in an 8–1 decision, the court sided with police and ruled that a "police officer's attempt to terminate a dangerous high-speed car chase that threatens the lives of innocent bystanders does not violate the Fourth Amendment, even when it places the fleeing motorist at risk of serious injury or death." [2] In a rare occurrence, the court accepted the presentation of video evidence of the high-speed pursuit. Such procedure is quite uncommon in the Supreme Court and was viewed as part of an interesting relationship between the Supreme Court and technology. The video had a strong effect on the Court's decision and is viewed as a major factor in how the court made its decision. [3] The author of the opinion, Justice Antonin Scalia, in a first-time occurrence ever, posted the video of the car chase online (for access to the video, see external links below).

Contents

Justice John Paul Stevens, the lone dissenter, argued that the videotape evidence was not decisive, as the majority claimed it to be, and that a jury should determine if deadly force was justified. He stated a jury should be used, instead of the case "being decided by a group of elderly appellate judges," a reference to himself and his colleagues on the court (this sentence is not in the text of the dissent, but he pronounced it while reading the opinion at bench). [4]

Three law professors created an experiment based on the video, showing it to over a thousand subjects and then asking them whether they thought the use of deadly force was reasonable. The study found "[a] fairly substantial majority did interpret the facts the way the Court did. But members of various subcommunities did not." The study and the disagreement over the reasonableness of the use of deadly force was reported in the Harvard Law Review. [5]

See also

Related Research Articles

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Deadly force, also known as lethal force, is the use of force that is likely to cause serious bodily injury or death to another person. In most jurisdictions, the use of deadly force is justified only under conditions of extreme necessity as a last resort, when all lesser means have failed or cannot reasonably be employed.

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<span class="mw-page-title-main">Car chase</span> Chase between two automobiles, often involving law enforcement

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Brendlin v. California, 551 U.S. 249 (2007), was a decision by the Supreme Court of the United States that held that all occupants of a car are "seized" for purposes of the Fourth Amendment during a traffic stop, not just the driver.

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The shooting deaths of Timothy Russell and Malissa Williams, two Black American individuals, occurred in East Cleveland, Ohio on November 29, 2012, at the conclusion of a 22-minute police chase which started in downtown Cleveland, when police erroneously claimed shots were fired at them as Russell and Williams drove by a squad car; the cause of the shots was their vehicle's exhaust pipe backfiring.

Rodriguez v. United States, 575 U.S. 348 (2015), was a United States Supreme Court case which analyzed whether police officers may extend the length of a traffic stop to conduct a search with a trained detection dog. In a 6–3 opinion, the Court held that officers may not extend the length of a traffic stop to conduct a dog sniff unrelated to the original purpose of the stop. However, the Court remanded the case to the United States Court of Appeals for the Eighth Circuit to determine whether the officer's extension of the traffic stop was independently justified by reasonable suspicion. Some analysts have suggested that the Court's decision to limit police authority was influenced by ongoing protests in Ferguson, Missouri.

Navarette v. California, 572 U.S. 393 (2014), was a case in which the United States Supreme Court clarified when police officers may make arrests or conduct temporary detentions based on information provided by anonymous tips. In 2008, police in California received a 911 call that a pickup truck was driving recklessly along a rural highway. Officers spotted a truck matching the description provided in the 911 call and followed the truck for five minutes, but did not observe any suspicious behavior. Nevertheless, officers conducted a traffic stop and discovered 30 pounds (14 kg) of marijuana in the truck. At trial, the occupants of the car argued that the traffic stop violated the Fourth Amendment of the United States Constitution, because the tip was unreliable, and officers did not personally observe criminal activity. Writing for a majority of the Court, Justice Clarence Thomas held that the 911 call was reliable, and that officers need not personally observe criminal activity when acting upon information provided by an anonymous 911 call.

Mullenix v. Luna, 577 U.S. ___ (2015), was a case in which the Supreme Court of the United States held that a police officer who shot a suspect during a police pursuit was entitled to qualified immunity. In a per curiam opinion, the Court held that prior precedent did not establish "beyond debate" that the officer's actions were objectively unreasonable.

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Plumhoff v. Rickard, 572 U.S. 765 (2014), is a United States Supreme Court case involving the use of force by police officers during high-speed car chases. After first holding that it had jurisdiction to hear the case, the Court held that the conduct of the police officers involved in the case did not violate the Fourth Amendment to the U.S. Constitution, which prohibits unreasonable searches and seizures.

Barnes v. Felix is a pending United States Supreme Court case on excessive force claims under the Fourth Amendment. The court will decide whether courts should apply the “moment of the threat” doctrine, which looks only at the narrow window in which a police officer's safety was threatened to determine whether his actions were reasonable, in evaluating claims that police officers used excessive force under the Fourth Amendment.

References

  1. "Court Sides With Cops On High-Speed Chase". CBS News. April 30, 2007. Retrieved April 30, 2007.
  2. "Supreme Court opinion" (PDF). Supreme Court of the U.S. Retrieved April 30, 2007.
  3. "Scott v. Harris: Impact on Law Enforcement". PoliceOne. Retrieved May 5, 2007.
  4. Associated Press."Court Sides With Cops On High-Speed Chase, Supreme Court Rejects Arguments Of Man Paralyzed in Crash Stemming From Police Pursuit", CBS News, April 30, 2007.
  5. "Whose Eyes Are You Going to Believe?: Scott v. Harris and the Perils of Cognitive Illiberalism, 122 Harv. L. Rev. 837 (2009)". April 12, 2009.