Scott v. Harris
Citation: 550 U.S. 372 (2007) Court: United States Supreme Court
Facts
Victor Harris led police on a high-speed car chase in Georgia after being clocked at 73 mph in a 55 mph zone. Officer Timothy Scott executed a PIT maneuver (ramming Harris’s car) after the chase reached dangerous speeds. Harris’s car crashed and he was left a quadriplegic. Harris sued Scott under § 1983 for excessive force. A videotape of the chase was in evidence. The lower courts denied summary judgment, crediting Harris’s account of events.
Issue
When a videotape blatantly contradicts the plaintiff’s version of the events leading to the use of force, must a court credit the plaintiff’s version of events for purposes of summary judgment?
Holding
No. The Supreme Court reversed, granting summary judgment to Officer Scott. When a plaintiff’s account is blatantly contradicted by objective evidence in the record — here, a videotape — a court should not adopt that version of the facts at summary judgment. The use of force was also reasonable given the serious threat Harris posed to the public.
Rule / Doctrine
Under the Graham v. Connor objective reasonableness standard, courts assess excessive force claims by examining what a reasonable officer would have done in the circumstances. Where objective evidence (such as video) conclusively contradicts a plaintiff’s account, the court need not view the facts in the light most favorable to the plaintiff for summary judgment purposes. A police officer’s decision to terminate a dangerous high-speed chase by ramming the fleeing vehicle can be constitutionally reasonable.
Significance
Scott v. Harris is significant both for its substantive holding — affirming broad police authority to use potentially deadly force to end dangerous high-speed chases — and for its procedural contribution to summary judgment doctrine: video evidence that conclusively contradicts a party’s account eliminates the genuine dispute of fact required to survive summary judgment. The case sparked scholarly debate about judicial fact-finding and the limits of the “reasonable officer” standard.