Supreme Court Reinforces Summary Judgment Standard in Section 1983, Qualified Immunity Context
From the United States Supreme Court this week comes a case that makes you scratch your head wondering why justice took so long to arrive for ordinary citizens. Imagine you are in your home after midnight on New Year’s Day when you hear a commotion outside your door. You open the door to find your teenage son lying on the porch and a police officer standing over him with his gun drawn. The officer tells you your son stole the car parked in front of your house, an obvious misunderstanding because you own the car. You tell the officer that the allegedly stolen car belongs to you.
Two more officers arrive on the scene. The first officer tells your wife to stand against the garage door. When she objects the officer, according to your family, grabs her arm and slams her against the garage door. When your son tells the officer to get his hands off his mother, the officer fires three shots. A bullet collapses your son’s right lung and pierces his liver, thus ending his promising professional baseball career and an injury that causes your son pain on a daily basis.
Now imagine that the trial court judge and two of three court of appeals judges decide that the officer was acting in the course of duty and is immune from being sued for his actions. How would you feel about that?
Fortunately, the United States Supreme Court breathed life back into the case and given the family its day in court. In a per curiam opinion with Justices Scalia and Alito offering a separate concurring opinion, the Court vacated the court of appeals’ decision in this Section 1983 case. The Court reiterated the legal principles that guide a court’s analysis of a state actor’s defense of qualified immunity, a doctrine that “balances two important interests—the need to hold public officials accountable when they exercise power irresponsibly and the need to shield officials from harassment, distraction, and liability when they perform their duties reasonably.” Pearson v. Callahan, 129 S.Ct. 808, 815 (2009). When evaluating the qualified immunity defense on summary judgment, courts must first determine whether there is evidence that the defendant’s conduct violated a federal constitutional right. This inquiry necessarily requires a balancing between the nature and quality of the intrusion on the plaintiff’s constitutional rights against the importance of the governmental interest justifying the intrusion. Here, the constitutional right at issue was the Fourth Amendment’s guarantee of freedom from unreasonable searches and seizures. The governmental interest was the officer’s right to protect himself. Next, courts must decide whether the right was clearly established at the time of the alleged violation. Officers cannot be liable when the right’s contours are murky or have not been defined or established by the courts.
The high Court did not decide that the officer is liable for his actions. Instead, the court decided the case based on the straightforward procedural rule that when deciding a motion for summary judgment a court must view the evidence in a light most favorable to the party opposing the motion. The Court recognized several factual disputes arising from the evidence presented by the parties, all of which focused on whether the officer acted in a reasonable manner under all of the surrounding circumstances, and whether he had a reasonable belief that he needed to protect himself. Genuine issues of material fact arose from contradictory evidence offered by the parties — whether the porch was dimly lit, whether the victim’s mother acted out of control, whether the victim rose to feet to protect his mother or whether he merely rose to his knees from off the ground. In the end, the Court decided that these and other factual disputes precluded summary judgment.
The case will now go back to the trial court for further proceedings. You can read the Supreme Court’s opinion here: Tolan v. Cotton, 572 U.S. ___ (May 5, 2014).