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Scott v. Harris

Supreme Court of the United States · 2007 · Civil Procedure

Civil Proceduresummary judgmentvideo evidencegenuine disputepolice chasesummary judgmentRule 56video evidence

Facts

A Georgia deputy tried to stop Harris for driving 73 miles per hour in a 55-mile-per-hour zone, but Harris fled, leading officers on a nighttime chase at speeds exceeding 85 miles per hour. During the pursuit, Harris evaded being boxed in at a shopping center, collided with Scott's police car, and sped away again, after which Scott took the lead. About six minutes and nearly ten miles into the chase, Scott used his push bumper on the rear of Harris's vehicle, causing Harris to lose control, leave the roadway, crash, and suffer severe injuries. A videotape in the record captured the chase and, according to the Court, showed Harris driving in a manner that posed an actual and imminent threat to others.

Issue

When ruling on summary judgment, must a court accept the nonmoving party's account when a videotape in the record blatantly contradicts that account? And under the Fourth Amendment, was Scott's use of force to end this dangerous high-speed chase objectively unreasonable?

Rule

At summary judgment, courts view facts in the light most favorable to the nonmoving party only where there is a genuine dispute; when one party's version is blatantly contradicted by the record so that no reasonable jury could believe it, a court should not adopt that version. Under the Fourth Amendment, reasonableness is determined by balancing the nature and quality of the intrusion on the individual's interests against the governmental interests justifying it, and an officer's attempt to terminate a dangerous high-speed chase threatening innocent bystanders does not violate the Fourth Amendment even if it places the fleeing motorist at risk of serious injury or death.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a § 1983 suit filed in federal court in Phoenix, Lena Ortiz claims an officer slammed her to the ground while she stood still with her hands raised. The officer moves for summary judgment and submits an undisputed body-camera recording that clearly shows Lena sprinting toward a locked gate, turning, and shoving the officer before the takedown. Lena does not claim the recording was altered or inaccurate.

How should the court treat Lena's version of events at summary judgment?

Explanation. At summary judgment, courts view facts in the light most favorable to the nonmoving party only when there is a genuine dispute. When the nonmovant's story is blatantly contradicted by the record so that no reasonable jury could believe it, the court should not adopt that version. Because the unchallenged recording clearly disproves Lena's account, the court should use the facts as depicted by the video.