Brower v. County of Inyo
Citation and Court
489 U.S. 593 (1989) — Supreme Court of the United States
Facts
William Caldwell was killed when the car he was driving, fleeing police at high speed, crashed into a roadblock set up by officers: a tractor-trailer hidden around a curve with police cars’ headlights aimed to blind approaching drivers. His heirs brought a Section 1983 claim alleging an unconstitutional seizure. The question was whether any Fourth Amendment seizure had occurred.
Issue
Does a Fourth Amendment seizure occur when police, intending to stop a fleeing suspect, cause the suspect’s death through a roadblock or other means deliberately applied?
Holding
Yes; a Fourth Amendment seizure occurs when there is a governmental termination of freedom of movement through means intentionally applied, i.e., when the force used was designed to and did interrupt the suspect’s freedom of movement.
Rule / Doctrine
A Fourth Amendment seizure of a person occurs when (1) there is a governmental termination of freedom of movement (2) through means intentionally applied. Accidental or negligent application of force does not constitute a seizure; only intentional governmental conduct that actually stops the person qualifies.
Significance
Brower clarifies the definition of “seizure” in the deadly-force and roadblock context, distinguishing intentional from accidental governmental conduct. It establishes that a seizure need not involve an arrest or brief stop—any intentional governmental act that terminates a person’s freedom of movement is a seizure subject to Fourth Amendment reasonableness review.