County of Sacramento v. Lewis

United States Supreme Court
523 U.S. 833 (1998)

ELI5:

Rule of Law:

For a high-speed police pursuit to result in a violation of substantive due process, the officer's conduct must do more than show deliberate or reckless indifference to life; it must shock the conscience by demonstrating a purpose to cause harm unrelated to the legitimate object of arrest.

Facts:

Sheriff's Deputy James Everett Smith and another officer, Murray Stapp, were responding to an unrelated call to break up a fight.
A motorcycle operated by 18-year-old Brian Willard, carrying 16-year-old Philip Lewis as a passenger, approached at high speed.
After Stapp attempted to block the motorcycle, Willard maneuvered between the police cars and sped off.
Smith immediately initiated a pursuit with his lights and siren activated.
The chase lasted for 75 seconds over 1.3 miles in a residential neighborhood, reaching speeds of up to 100 mph, with Smith following as closely as 100 feet behind the motorcycle.
The chase ended when Willard attempted a sharp turn, causing the motorcycle to tip over and throwing both riders to the ground.
Smith's patrol car, unable to stop in time, skidded into Lewis, killing him.

Procedural Posture:

Philip Lewis’s parents sued Sacramento County and Deputy Smith in the U.S. District Court, alleging a deprivation of Lewis's Fourteenth Amendment substantive due process rights under 42 U.S.C. § 1983.
The District Court granted summary judgment for Deputy Smith, ruling that he was entitled to qualified immunity because the law was not clearly established.
Lewis's parents, as appellants, appealed the decision to the U.S. Court of Appeals for the Ninth Circuit.
The Ninth Circuit reversed the District Court's summary judgment, holding that 'deliberate indifference' was the proper standard and that the law was clearly established, thus defeating qualified immunity.
Sacramento County and Deputy Smith, as petitioners, petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does a police officer violate the Fourteenth Amendment’s substantive due process guarantee by causing death through deliberate or reckless indifference to life in a high-speed automobile chase aimed at apprehending a suspected offender?

Opinions:

Majority - Justice Souter

No. A police officer's conduct in a high-speed chase does not violate substantive due process unless it shocks the conscience, which in this context requires a purpose to cause harm unrelated to the legitimate object of arrest. The Court reasoned that substantive due process protects against arbitrary government action, and the benchmark for executive abuse of power is conduct that 'shocks the conscience.' While 'deliberate indifference' may be sufficient in settings where state officials have time for deliberation, such as in providing medical care to pretrial detainees, it is not the appropriate standard for high-pressure, rapidly evolving situations like a police pursuit. These situations are more analogous to a prison riot, where officials must make split-second judgments under pressure. Therefore, to constitute a due process violation, the officer's conduct must rise to a level of culpability beyond recklessness, showing a malicious or sadistic purpose to cause harm.

Concurring - Justice Kennedy

Yes, I agree that the 'shocks the conscience' test applies, but it must be understood as an objective standard guided by legal traditions and the necessities of law enforcement. The Court’s reasoning correctly establishes objective considerations as the controlling principle. To find a constitutional violation for unintended injuries in a police pursuit would create a dangerous incentive for suspects to flee lawful commands, increasing the risk of accidents. The needs of law enforcement justify not finding a due process violation when unintended injuries occur after police pursue a suspect who disobeys a lawful order to stop.

Concurring - Justice Stevens

I concur in the judgment only. The Court should have avoided deciding the difficult and unresolved constitutional question. Instead, it should have reinstated the District Court's judgment on the grounds of qualified immunity, as the law regarding substantive due process in high-speed chases was not clearly established in 1990. Deciding novel constitutional questions is better left for suits against municipalities, where qualified immunity is not a defense.

Concurring - Justice Scalia

I concur in the judgment but reject the majority's 'shocks the conscience' test as an atavistic and subjective standard. The proper inquiry for a substantive due process claim, as established in Washington v. Glucksberg, is whether the asserted right is 'deeply rooted in this Nation’s history and tradition.' The respondents have provided no historical or precedential support for a right to be free from reckless police conduct during a car chase. Creating such a right would improperly transform the Fourteenth Amendment into a 'font of tort law,' supplanting the policy choices made by the people of California through their elected representatives.

Analysis:

This decision significantly raises the threshold for plaintiffs to succeed in § 1983 substantive due process claims arising from high-speed police pursuits. The Court created a clear distinction between custodial situations, where 'deliberate indifference' may suffice for liability because officials have time to reflect, and emergency situations, where a much higher 'purpose to harm' standard applies. By aligning the standard for police pursuits with the more stringent standard used for prison riots, the ruling provides law enforcement with substantial protection from constitutional liability for actions taken in rapidly evolving, high-pressure environments. This makes it extremely difficult for a plaintiff to prevail without evidence of a malicious or sadistic intent on the part of the officer.

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