Citation: 550 U.S. 372 (2007)
Court: Supreme Court of the United States
Oral Argument: February 26, 2007
Decision Date: April 30, 2007
Court Below: United States Court of Appeals for the Eleventh Circuit
Scott v. Harris is a landmark Supreme Court case addressing the Fourth Amendment, police use of force, and qualified immunity in the context of a high-speed car chase. The case arose after a fleeing motorist, Victor Harris, was seriously injured and left a quadriplegic when a police officer terminated a chase by making direct contact with Harris’s vehicle.
The Supreme Court was asked to determine whether the officer’s actions violated the Fourth Amendment’s prohibition on unreasonable seizures and whether the officer was protected by qualified immunity. A significant feature of the case was the Court’s reliance on video evidence of the chase, which played a major role in how the facts were evaluated.
Facts of Scott v. Harris Case
Because the appeal arose from a denial of summary judgment, no facts had been found by a jury. For purposes of the motion, the lower courts were required to view the evidence in the light most favorable to Harris, the nonmoving party.
On March 29, 2001, Coweta County law enforcement officers observed Victor Harris driving 73 miles per hour in a 55-mile-per-hour zone. When an officer attempted to stop him, Harris sped away, passing vehicles on double yellow lines and running a red light.
Officer Timothy Scott joined the pursuit after hearing a radio call, believing it might be related to an undercover drug operation. The chase lasted approximately six minutes, with speeds averaging between 80 and 90 miles per hour.
Harris entered an empty parking lot, where Scott tried unsuccessfully to block his exit. After a minor collision, Harris accelerated away again, and the chase continued. Officers from other jurisdictions took steps to block intersections and clear traffic, though Scott was unaware of those actions.
Scott requested permission from his supervisor to perform a Precision Intervention Technique (PIT maneuver), designed to spin a fleeing vehicle to end a pursuit. He had not been trained in the maneuver but was granted authorization.
During the chase, Scott concluded that a proper PIT maneuver was not feasible due to the speed and instead made direct contact with the rear of Harris’s vehicle. Harris lost control, left the roadway, and rolled down an embankment. He was not wearing a seatbelt and suffered catastrophic injuries, becoming a quadriplegic.
Procedural History
Harris filed several claims related to the incident. All were dismissed except for a § 1983 claim against Officer Scott in his individual capacity, alleging excessive force in violation of the Fourth Amendment. Scott moved for summary judgment, asserting qualified immunity.
The district court denied the motion, finding that a jury could conclude Scott used excessive force. The Eleventh Circuit affirmed, holding that Scott’s conduct could be considered deadly force and that clearly established law at the time gave Scott notice that such conduct was unconstitutional. Scott appealed to the Supreme Court.
Issues Presented
In Scott v. Harris, the Supreme Court considered two principal issues. First, whether Harris could show that his Fourth Amendment rights were violated when Scott used force to end the pursuit by ramming his vehicle. Second, whether clearly established law in 2001 gave a reasonable police officer fair warning that such conduct would violate the Fourth Amendment, thereby defeating qualified immunity.
Arguments of the Parties
Harris argued that Scott’s actions constituted deadly force and that, under Tennessee v. Garner, deadly force is permissible only when necessary to prevent escape and when the suspect poses an immediate threat to human life. Harris maintained that he was a fleeing traffic offender and did not pose such a threat.
Scott responded that the force used should not be classified as deadly force and that the proper standard was general objective reasonableness under the Fourth Amendment. Scott further argued that, regardless of the standard, he was entitled to qualified immunity because his actions did not violate clearly established constitutional law.
Supreme Court’s Analysis in Scott v. Harris
The Supreme Court reversed the Eleventh Circuit. Writing for the majority, Justice Antonin Scalia emphasized that courts evaluating summary judgment must adopt the nonmoving party’s version of the facts only when there is a genuine dispute.
In this case, the Court relied heavily on a videotape of the chase, which was introduced into evidence. After viewing the video, the Court concluded that no reasonable jury could believe Harris’s version of events where it conflicted with what the videotape clearly showed.
The Court described the chase as one that posed a severe risk to public safety, noting Harris’s high speeds and dangerous driving behavior. Based on the video evidence, the Court held that Scott’s attempt to terminate the chase was objectively reasonable in light of the threat to innocent bystanders.
The majority declined to engage Harris’s argument that deadly force is permissible only against dangerous fleeing felons known to have committed violent crimes, stating that Harris’s conduct itself created an “extreme danger to human life.”
In Scott v. Harris, the Court held that because Scott’s actions were reasonable under the Fourth Amendment, there was no constitutional violation. As a result, Scott was entitled to qualified immunity without needing to decide whether the law was clearly established.
Concurring and Dissenting Opinions
Justice Stephen Breyer concurred, agreeing with the outcome and adding comments on the sequential analysis required by Saucier v. Katz. Justice Ruth Bader Ginsburg also concurred, emphasizing that excessive force cases are fact-dependent and must be evaluated case by case using a flexible, factor-based approach.
Justice John Paul Stevens dissented. He argued that the videotape was not as conclusive as the majority claimed and that a jury should decide whether Scott’s use of force was justified. Stevens expressed concern about appellate judges substituting their own judgment for that of a jury in resolving contested factual issues.
Conclusion
Scott v. Harris stands as a key Supreme Court decision on Fourth Amendment reasonableness, qualified immunity, and police use of force during vehicle pursuits. By focusing on the objective risk posed to public safety and relying on video evidence, the Court concluded that the officer’s actions did not violate the Constitution.
The case continues to shape how courts analyze police conduct in rapidly evolving, dangerous situations and illustrates the importance of concrete evidence in constitutional litigation. Through its reasoning and outcome, Scott v. Harris remains a significant reference point in excessive force jurisprudence under US law.