Scott v. Harris

Following is the case brief for Scott v. Harris, 550 U.S. 372 (2007)

Case Summary of Scott v. Harris:

  • Officer Scott ended a high-speed car chase with Respondent Harris by running into the back of Harris’s car, causing Harris to crash and suffer severe injuries.
  • Harris sued Scott for violating his Fourth Amendment right against unreasonable searches and seizures.  The trial court denied Scott’s summary judgment motion.
  • The Court of Appeals affirmed the trial court’s decision, finding that the issue of qualified immunity for Scott should be decided by a jury.
  • The U.S. Supreme Court reversed.  It held that the Fourth Amendment is not violated when a police officer takes action to stop a fleeing motorist from putting innocent bystanders at risk, even if the action places the motorist at risk of serious bodily injury or death.

Scott v. Harris Case Brief

Statement of the Facts:

Respondent Harris was driving 73 mph in a 55 mph zone.  Police began pursuit.  Rather than pull over in response to police sirens and lights, Harris sped up.  At one point during the pursuit, Harris’s car was almost cornered in a parking lot.  However, Harris made one sharp turn, ran into Officer Scott’s police vehicle, and was able to flee the parking lot.  At that point, Officer Scott led the pursuit.

About 10 minutes into the high-speed chase, Officer Scott requested, and received, permission to engage in a maneuver that would cause Harris’s car to spin to a stop.  Scott, however, pushed his bumper into the rear of Harris’s car, causing Harris to crash.  Harris’s injuries as a result of the crash left him a quadriplegic.

Procedural History:

  • Harris sued Scott and others in Federal District Court.  He alleged that Scott violated his Fourth Amendment right against unreasonable searches and seizures.
  • The District Court denied Scott’s summary judgment motion.  It found that there were issues of fact to regarding whether Scott should get qualified immunity.
  • The Eleventh Circuit Court of Appeals affirmed.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Can a police officer take actions that may put a fleeing motorist at risk of serious bodily injury in order to stop the motorist from putting innocent bystanders at risk?  Yes.

Judgment:

The judgment of the Eleventh Circuit Court of Appeals is reversed.

Rule of Law or Legal Principle Applied:

It is not a violation of the Fourth Amendment when a police officer takes action to stop a fleeing motorist from putting innocent bystanders at risk, even if the action places the motorist at risk of serious bodily injury or death.

Reasoning:

Under Saucier v. Katz, 533 U.S. 194 (2001), resolving questions of qualified immunity first requires a determination of whether the officer violated a constitutional right.  In evaluating the facts for that determination, the Court of Appeals should have looked at the videotape of the chase, not followed the facts as recited by Harris.  The videotape of the car chase showed Harris’s extreme recklessness such that no reasonable juror could believe Harris’s version of the chase.

Judging the matter based on the videotape, there was clearly no violation of the Fourth Amendment.  Officer Scott’s behavior was objectively reasonable because he made the choice to put a fleeing suspect at risk to avoid putting innocent people at further risk.  Calling off the chase would not have solved the issue of Harris’s danger to others.  Accordingly, because no constitutional right was violated, Scott was entitled to qualified immunity and summary judgment in this case.

Concurring Opinion (Ginsburg):

First, the Court’s opinion should not be viewed as reciting a mechanical rule, but rather a fact-sensitive “reasonableness” assessment.  Second, the Court should leave for another day the notion of confronting Saucier’s requirement that a court make a constitutional determination as the initial inquiry.

Concurring Opinion (Breyer):

The video makes clear how fact-dependent the inquiry must be.  That fact dependency suggests that the Court overrule the Saucier requirement that courts must make a threshold constitutional determination.  Courts should typically avoid such constitutional determinations whenever possible.

Dissenting Opinion (Stevens):

The Court was wrong to make a de novo assessment of the facts of the chase based on the videotape, rather than rely on the well-settled standard of review of factual determinations made by lower courts.  The Court of Appeals assessment of the facts was accurate when compared to the video.  Further, a motorist leading police in a high-speed chase is a serious offense.  It is not, however, an offense that justified the use of deadly force.

Significance:

Scott v. Harris is unusual because the Court made a de novo review of the facts in the case. Typically, appellate courts rely on the factual record formed in the courts below, particularly because trial courts are closer to the facts than an appellate court.

Student Resources:

https://supreme.justia.com/cases/federal/us/550/372/opinion.html

https://www.oyez.org/cases/2006/05-1631

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