572 U.S. 765 (2014)
On July 18, 2004, near midnight, Lieutenant Joseph Forthman of the West Memphis, Arkansas, Police Department pulled over a white Honda Accord driven by Donald Rickard because the car had only one operating headlight.1 Kelly Allen rode in the passenger seat.2 Forthman noticed an indentation roughly the size of a head or a basketball in the windshield, asked Rickard if he had been drinking, and received a negative response. Rickard failed to produce his driver's license upon request and appeared nervous, prompting Forthman to direct him to step out of the car.3 Rickard instead sped away.4
Forthman gave chase and was soon joined by five other police cruisers driven by Sergeant Vance Plumhoff and Officers Jimmy Evans, Lance Ellis, Troy Galtelli, and John Gardner.5 The pursuit proceeded east on Interstate 40 toward Memphis, Tennessee.6 The vehicles attained speeds over 100 miles per hour, passed more than two dozen other vehicles, and officers attempted without success to stop Rickard using a rolling roadblock. Rickard eventually exited the interstate in Memphis and made a quick right turn that caused contact between his car and Evans' cruiser.7
Rickard's car spun out into a parking lot and collided with Plumhoff's cruiser.8 Rickard put the car into reverse in an attempt to escape.9 Evans and Plumhoff exited their cruisers and approached, with Evans pounding on the passenger-side window while holding his gun.10 Rickard's car made contact with another cruiser, its tires began spinning, and the vehicle rocked back and forth with its bumper flush against a police cruiser. Plumhoff fired three shots into Rickard's car.11 Rickard then reversed in a 180-degree arc, maneuvered onto another street, and continued fleeing, forcing Ellis to step to his right to avoid the vehicle.12
As Rickard fled down that street, Gardner and Galtelli fired twelve additional shots. Rickard lost control of the car and crashed into a building.13 Rickard and Allen both died from some combination of gunshot wounds and injuries suffered in the crash.14 Rickard's minor daughter, through her mother as parent and next friend, filed a suit under 42 U.S.C. §1983 against the six officers, the mayor, and the chief of police of West Memphis, alleging that the officers used excessive force in violation of the Fourth and Fourteenth Amendments.15 The officers moved for summary judgment based on qualified immunity, which the District Court denied.16 The officers appealed.17 A Sixth Circuit motions panel initially dismissed the appeal for lack of jurisdiction but later granted rehearing and left the jurisdictional issue for the merits panel.18 The merits panel affirmed the District Court's order.19 The Supreme Court granted certiorari.20
Whether the Court of Appeals properly exercised jurisdiction under 28 U.S.C. §1291 to review the district court's denial of the officers' motion for summary judgment based on qualified immunity?21
Under 28 U.S.C. §1291, courts of appeals have jurisdiction over final decisions of district courts.22 Orders denying summary judgment are generally not final.23 An exception applies when the denial is based on qualified immunity because such orders conclusively determine an important issue separate from the merits that cannot be effectively reviewed after final judgment, as established in Mitchell v. Forsyth and Johnson v. Jones.24 However, this exception does not extend to orders that merely decide questions of evidence sufficiency.25
Yes. The District Court denied the officers' motion for summary judgment asserting qualified immunity.26 The court viewed the facts in the light most favorable to Rickard's daughter.27 The Sixth Circuit merits panel affirmed that denial after initially addressing jurisdiction.28
The officers' appeal raised purely legal questions about whether their conduct violated the Fourth Amendment and whether any such violation was clearly established at the time.29 This differed from disputing which facts could be proved at trial as in Johnson v. Jones.30 These legal determinations fall within the core responsibility of appellate courts and impose no undue burden.31 This is consistent with the approach taken in Scott v. Harris where jurisdiction was likewise upheld over a similar qualified immunity denial.32
The Court of Appeals properly exercised jurisdiction under 28 U.S.C. §1291.33
Whether the officers violated the Fourth Amendment by using deadly force to terminate the high-speed car chase?34
A claim of excessive force by law enforcement is governed by the Fourth Amendment's reasonableness standard.35 The standard requires careful balancing of the nature and quality of the intrusion on the individual's Fourth Amendment interests against the countervailing governmental interests at stake.36 This analysis is from the perspective of a reasonable officer on the scene, as set forth in Graham v. Connor.37 Under this standard, a police officer's attempt to terminate a dangerous high-speed car chase that threatens the lives of innocent bystanders does not violate the Fourth Amendment even when it places the fleeing motorist at risk of serious injury or death, per Scott v. Harris.38
No. On July 18, 2004, near midnight, Lieutenant Forthman pulled over Donald Rickard's white Honda Accord for having only one operating headlight, noticed an indentation roughly the size of a head or basketball in the windshield, and directed Rickard to exit after he failed to produce a driver's license and appeared nervous; Rickard instead sped away, leading to a chase joined by Sergeant Plumhoff and Officers Evans, Ellis, Galtelli, and Gardner that exceeded 100 miles per hour for more than five minutes on Interstate 40, passed more than two dozen other vehicles, and involved an unsuccessful rolling roadblock attempt. After exiting the interstate, Rickard's car spun out into a parking lot after contact with Evans' cruiser, collided with Plumhoff's cruiser, and then rocked back and forth with its bumper flush against a police cruiser while Rickard used the accelerator in an attempt to escape; Plumhoff fired three shots, after which Rickard reversed in a 180-degree arc and continued fleeing down another street. Under these circumstances, all that a reasonable officer could have concluded was that Rickard was intent on resuming his flight and would again pose a deadly threat to others on the road, making the use of deadly force reasonable to end the grave public safety risk.39
The officers did not violate the Fourth Amendment by using deadly force to terminate the high-speed car chase.40
Whether the officers violated the Fourth Amendment by firing a total of fifteen shots during the incident?41
If police officers are justified in firing at a suspect to end a severe threat to public safety, they need not stop shooting until the threat has ended.42 The question is whether the officers violated the fleeing driver's personal Fourth Amendment rights rather than those of any passenger, whose presence cannot enhance the driver's rights or render the force excessive.43
No. During the ten-second span when all fifteen shots were fired, Rickard never abandoned his attempt to flee.44 He managed to drive away despite the officers' efforts to block his path before eventually crashing into a building.45 The presence of passenger Kelly Allen in the front seat does not alter the analysis because Fourth Amendment rights are personal rights that may not be vicariously asserted.46 It was Rickard who placed Allen in danger by fleeing and refusing to end the chase.47
The officers did not violate the Fourth Amendment by firing a total of fifteen shots during the incident.48
Whether the officers were entitled to qualified immunity on the ground that their conduct did not violate clearly established law at the time?49
An official sued under 42 U.S.C. §1983 is entitled to qualified immunity unless it is shown that the official violated a statutory or constitutional right that was clearly established at the time of the challenged conduct.50 Existing precedent must have placed the statutory or constitutional question beyond debate and not defined the right at a high level of generality.51 Brosseau v. Haugen demonstrates that as of February 21, 1999, it was not clearly established that it was unconstitutional to shoot a fleeing driver to protect those whom his flight might endanger.52
Yes. Respondent failed to meaningfully distinguish Brosseau or point to any controlling authority or robust consensus of cases of persuasive authority decided between February 21, 1999, and July 18, 2004, that would alter the qualified immunity analysis, as the facts here are more favorable to the officers than those in Brosseau where there was no ongoing high-speed chase and the officer fired only one shot.53 The District Court cited only Vaughan v. Cox, whose facts bear little resemblance because the suspect there merely accelerated to eighty to eighty-five miles per hour without engaging in evasive maneuvers, and no other case from that period clearly established the unconstitutionality of using lethal force to end a high-speed car chase.54
The officers were entitled to qualified immunity on the ground that their conduct did not violate clearly established law at the time.55