Lexplug logoLexplug

Hunt ex rel. DeSombre v. State, Department of Safety & Homeland Security

Supreme Court of Delaware
2013 WL 3193549, 2013 Del. LEXIS 315, 69 A.3d 360 (2013)
ELI5:

Rule of Law:

It is an unreasonable seizure under the Fourth Amendment for a police officer to detain and intentionally frighten a non-suspect student for the sole purpose of eliciting a confession from another student. Such conduct is a violation of a clearly established right, thereby overcoming the officer's qualified immunity.


Facts:

  • A vice principal, David McDowell, was investigating a bullying incident where a student, 'AB', allegedly stole one dollar from an autistic student on a school bus.
  • AB denied taking the money and claimed another student who sat next to him, eight-year-old Anthony J. Hunt, was the perpetrator.
  • McDowell asked School Resource Officer David Pritchett to speak with AB about the incident.
  • Pritchett, despite being 'virtually certain' that Hunt was innocent, identified Hunt from a bus seating chart.
  • Without notifying Hunt's parents or seeking permission from McDowell, Pritchett brought Hunt into a room with AB for questioning.
  • Pritchett closed the door and, using a 'mean voice,' repeatedly threatened Hunt with arrest and placement in a juvenile detention facility.
  • Pritchett's actions caused Hunt to cry, which then prompted AB to confess to taking the money.
  • Following the incident, Hunt withdrew from school and was homeschooled for the remainder of the school year.

Procedural Posture:

  • Lisa DeSombre, on behalf of her son Anthony J. Hunt, filed a lawsuit against Trooper Pritchett and other state and school district defendants in the Delaware Superior Court, a trial court.
  • The claims against the school district defendants were resolved separately.
  • Pritchett filed a motion for summary judgment on all remaining claims against him.
  • The Superior Court granted summary judgment in favor of Pritchett.
  • Hunt, as the appellant, appealed the trial court's grant of summary judgment to the Supreme Court of Delaware, the state's highest court.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a police officer's detention and interrogation of an eight-year-old student, whom the officer does not suspect of any wrongdoing, for the purpose of intentionally frightening him to elicit a confession from another student, constitute an unreasonable seizure in violation of the Fourth Amendment?


Opinions:

Majority - Berger, Justice

Yes. A police officer's detention of a non-suspect student for the purpose of intentionally frightening him to secure a confession from another student is an unreasonable seizure under the Fourth Amendment. A seizure occurred because a reasonable eight-year-old, confronted by a uniformed officer in a closed room, would not have felt free to leave. The seizure was unreasonable because its purpose was not a legitimate investigation into Hunt's conduct—as Pritchett admittedly knew Hunt was innocent—but rather to use Hunt as an instrumental pawn to intimidate AB into confessing. Citing precedent like New Jersey v. T.L.O. and Shuman v. Penn Manor School District, the court found this purpose falls outside the bounds of reasonableness required for seizures in a school setting. Furthermore, the right to be free from such an unreasonable seizure was 'clearly established,' meaning a reasonable officer should have known the conduct was unlawful, thus defeating Pritchett's claim of qualified immunity.



Analysis:

This decision clarifies the application of the Fourth Amendment's reasonableness standard for seizures of students by law enforcement in a school setting. The ruling emphasizes that the purpose of the seizure is a critical component of the reasonableness analysis. It establishes a precedent that using a non-suspect child as an instrument of interrogation against another student is an unconstitutional seizure. This holding narrows the scope of qualified immunity for school resource officers, putting them on notice that their actions must be tied to a legitimate investigative or disciplinary purpose related to the specific student being seized.

🤖 Gunnerbot:
Query Hunt ex rel. DeSombre v. State, Department of Safety & Homeland Security (2013) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.
Locked
Subscribe to Lexplug to chat with the Gunnerbot about this case.

Unlock the full brief for Hunt ex rel. DeSombre v. State, Department of Safety & Homeland Security