27 May 2014

Law in Plain English: Plumhoff v. Rickard

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogPlumhoff v. Rickard

Argument: Mar 4 2013

Discussion: In March 2001, a police officer in Georgia rammed a vehicle from behind to stop it following a high speed chase. As a result of the ramming, the suspect lost control of his vehicle, which left the roadway, ran down an embankment, overturned, and crashed. The suspect was badly injured and was rendered a quadriplegic. In 2007, the Supreme Court ruled that a police officer did not violate the constitutional rights of a suspect when he tried to terminate a chase by ramming the car from behind. In a July 2004 chase, three West Memphis police officers fired shots into a vehicle that had repeatedly rammed police cruisers and (allegedly) revved its engine when the officers surrounded the vehicle. Both occupants of the vehicle were killed. On constitutional claims under 42 USC § 1983, the District Court determined that the officers were not entitled to qualified immunity for their actions. The Sixth Circuit affirmed, and analyzed the 2004 incident using the standard set by the Supreme Court in the 2007 case, as opposed to the clearly established law that existed at the time of the 2004 incident. In other words, the Sixth Circuit analyzed the case under a standard that did not exist when the incident occurred.

Issue: The questions before the Court are (1) whether the Sixth Circuit wrongly denied qualified immunity to the petitioners by analyzing whether the force used in 2004 was distinguishable from factually similar force ruled permissible three years later in Scott v. Harris. Stated otherwise, the question presented is whether, for qualified immunity purposes, the Sixth Circuit erred in analyzing whether the force was supported by subsequent case decisions as opposed to prohibited by clearly established law at the time the force was used; and (2) whether the Sixth Circuit erred in denying qualified immunity by finding the use of force was not reasonable as a matter of law when, under the respondent's own facts, the suspect led police officers on a high-speed pursuit that began in Arkansas and ended in Tennessee, the suspect weaved through traffic on an interstate at a high rate of speed and made contact with the police vehicles twice, and the suspect used his vehicle in a final attempt to escape after he was surrounded by police officers, nearly hitting at least one police officer in the process.

Holding: In a 9-0 decision, the Supreme Court ruled that the officers' conduct did not violate the Fourth Amendment because they acted reasonably in using deadly force; they did not fire more shots than necessary to end the public safety risk. Even if the officers' conduct had violated the Fourth Amendment, the officers would still be entitled to summary judgment based on qualified immunity.
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