In March 2001, a Georgia police officer recorded Victor Harris traveling 73 mph in a 55 mph zone. The officer initiated pursuit, but Harris refused to stop. The officer requested support, and Deputy Timothy Scott joined the pursuit. Eventually, Scott requested and received permission to use a Precision Intervention Technique ("PIT") maneuver, which would cause Harris's vehicle to spin to a stop. Scott accelerated and tapped the rear bumper of Harris's car, causing him to lose control and crash.
Harris filed a civil rights action in federal court, alleging that Scott had violated the Fourth Amendment by using excessive force. Scott responded by filing a motion for summary judgment, asserting qualified immunity. The district court denied the motion for summary judgment, and the circuit court affirmed. The Supreme Court granted certiorari and reversed 8-1, holding that Scott was entitled to qualified immunity because Harris was driving recklessly and posed an immediate risk of serious harm to the public.
The key issue was the determination of the relevant facts. When deciding a summary judgment motion, courts are required to view the facts and draw reasonable inferences in the light most favorable to the party opposing the motion. In other words, in the defendant files a motion for summary judgment, the court is required to view the facts in the light most favorable to the plaintiff.
In this case, Harris alleged that he was driving safely and did not endanger the public. However, Scott introduced into evidence two videotapes of the incident, made by cameras in the two police cars. The Supreme Court held that the facts on summary judgment must be viewed in the light most favorable to the nonmoving party only if there is a genuine dispute as to those facts, and that the videotape conclusively showed that Harris was driving recklessly. Justice Stevens dissented, arguing that the videotape did not conclusively show that Harris was driving recklessly.
These are the two videos in question.
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