County of Sacramento v. Lewis
Encyclopedia
Sacramento v. Lewis, , was a decision of the Supreme Court of the United States
involving police action in a high-speed car chase
.
The majority opinion based this on an analysis of the 14th Amendment due process
concept and an application of the "shocks the conscience
" test. Prior cases have held that the “core” of due process concept is “protection of the individual against arbitrary action of government.” In dealing with executive action, only the “most egregious” conduct is “arbitrary in constitutional sense."
In determining what is "egregious" action, one should consider whether such action "shocks the conscience" (Rochin v. California
, 1953). One must also consider culpability: in this case, we are dealing with "recklessness." Finally, the decision should not be made “mechanically” for one should consider the context.
In this case, the “deliberate indifference” accusation does not make sense, since in a high-speed chase there is no time for deliberation. Furthermore, one must remember that officers are under instense pressure in these situations, where they must “act decisively and show restraint at the same time." Thus the Court held: “High-speed chases with no intent to harm suspects physically or to worsen their legal plight do not give rise to liability under the Fourteenth Amendment”
In Kennedy's concurrence, he warned that the “shock the conscience” test should be treated with skepticism due to its subjective nature. However, he recognized it as a good starting point for comparing the “objective nature” of certain actions with precedent, history, and tradition. When considering the test, one need to take into the account the “necessities” of law enforcement: It
would be counterproductive to suggest that “suspects may ignore a lawful command to stop and then sue for damages sustained in an ensuing chase”
Scalia's concurrence noted the irony in applying the “shocks the conscience” test in this case, since only last term the Court rejected it (Washington v. Glucksberg
, 1997). He agreed with the Court, not because of the “shocks the conscience” test, but because the petitioners had presented no support for their “alleged due process right.”
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
involving police action in a high-speed car chase
Car chase
A car chase is the vehicular pursuit of a suspect by law enforcement officers. Car chases are often captured on film and broadcast due to the availability of video footage recorded by police cars and police and media helicopters participating in the chase...
.
Background
This case concerned a high-speed chase between Sacramento County sheriff’s deputies and two men on a motorcycle: Brian Willard driving and Phillip Lewis as a passenger. The chase wove in and out of moving traffic and reached speeds up to 100 miles an hour, ending when Willard lost control and the bike tipped over. One of the deputies could not stop in time and hit Lewis, killing him. Lewis’ parents sued the county’s Sheriff’s Department, accusing the deputy of depriving Lewis of his Fourteenth Amendment due process right to life through deliberate and reckless conduct. A district court ruled in favor of the deputy, the Ninth Circuit appeals court reversed, and then the Supreme Court ruled unanimously in the department’s favor.Decision
The question before the Court was: Does a police officer violate substantive due process by causing death through reckless indifference to life in a high-speed chase aimed at apprehending a suspected offender? The answer was a unanimous "no."The majority opinion based this on an analysis of the 14th Amendment due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
concept and an application of the "shocks the conscience
Shocks the conscience
Shocks the conscience is a phrase used as a legal standard in the United States and Canada. An action is understood to "shock the conscience" if it is perceived as manifestly and grossly unjust, typically by a judge.-United States:...
" test. Prior cases have held that the “core” of due process concept is “protection of the individual against arbitrary action of government.” In dealing with executive action, only the “most egregious” conduct is “arbitrary in constitutional sense."
In determining what is "egregious" action, one should consider whether such action "shocks the conscience" (Rochin v. California
Rochin v. California
Rochin v. California, 342 U.S. 165 , was a case decided by the Supreme Court of the United States that added behavior that "shocks the conscience" into tests of what violates due process...
, 1953). One must also consider culpability: in this case, we are dealing with "recklessness." Finally, the decision should not be made “mechanically” for one should consider the context.
In this case, the “deliberate indifference” accusation does not make sense, since in a high-speed chase there is no time for deliberation. Furthermore, one must remember that officers are under instense pressure in these situations, where they must “act decisively and show restraint at the same time." Thus the Court held: “High-speed chases with no intent to harm suspects physically or to worsen their legal plight do not give rise to liability under the Fourteenth Amendment”
In Kennedy's concurrence, he warned that the “shock the conscience” test should be treated with skepticism due to its subjective nature. However, he recognized it as a good starting point for comparing the “objective nature” of certain actions with precedent, history, and tradition. When considering the test, one need to take into the account the “necessities” of law enforcement: It
would be counterproductive to suggest that “suspects may ignore a lawful command to stop and then sue for damages sustained in an ensuing chase”
Scalia's concurrence noted the irony in applying the “shocks the conscience” test in this case, since only last term the Court rejected it (Washington v. Glucksberg
Washington v. Glucksberg
Washington v. Glucksberg, 521 U.S. 702 , was a case in which the Supreme Court of the United States unanimously held that a right to assistance in committing suicide was not protected by the Due Process Clause.-Facts:Dr...
, 1997). He agreed with the Court, not because of the “shocks the conscience” test, but because the petitioners had presented no support for their “alleged due process right.”
See also
- List of United States Supreme Court cases, volume 523
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume