County of Sacramento v. Lewis PDF

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Summary

Constitutional Law II 2020 case brief for COUNTY OF SACRAMENTO...

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COUNTY OF SACRAMENTO v. LEWIS 523 U.S. 833 (1998) FACTS: Parties: Appellant: County of Sacramento (Δ) Appellee: Lewis (Π) Procedural History: 

District court granted SJ in favor of Π

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9th Circuit reversed

Relevant Facts: 

Smith, a sheriff’s deputy, responded to a call along with Stapp

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Stapp returned to his patrol car and saw a motorcycle, carrying Π as passenger, approaching at high speed

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Stapp turned on his rotating lights, yelled for the cycle to stop and pulled his car closer to Smith’s in an attempt to pen the cycle in

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Cycle maneuvered between the two cars and sped off

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Smith immediately switched on his own emergency lights and siren and began a high speed chase

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The chase ended after the cycle tipped over

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Smith slammed on his brakes but the car skidded into Π causes injuries and death

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Π brought claim of violation of due process right to life

ISSUE: 

Whether a police officer violates the 14th Amendment guarantee of due process when he causes a death through deliberate or reckless indifference to life in a high speed automobile chase

PARTIES’ ARGUMENTS: Appellant:  Appellee:

 DISPOSITION OF THE COURT: 

Reversed

RULE OF LAW: 

A police officer does not violate the 14th Amendment guarantee of due process when he causes a death through deliberate or reckless indifference to life in a high speed automobile chase; to reach that level, there must be evidence of intent to harm

HOLDING: 

Δ did not violate Π’s 14th Amendment right life by cause the death through deliberate or reckless indifference to life in the high speed chase

COURT’S REASONING:     

Π’s claims are insufficient to state a due process violation Only the most egregious executive action can be said to be arbitrary in the constitutional sense The action must shock the conscience Liability for negligently inflicted harm is categorically beneath the constitutional due process threshold Rules of due process are not subject to mechanical application in unfamiliar territory...