Project Draft
Len Q. Baptista
University of Maine at Presque Isle
CRJ 372: Final Project
Professor Reed Nonken
December 05, 2023
Legal Case: Scott v. Harris (2007)
The U.S. Supreme Court ruled in favor of the dependent in Scott v. Harris in 2007. The case arose from a high-speed vehicular pursuit that occurred in Georgia in 2001. The plaintiff, Victor Harris, a 19-year-old driver of the fleeing vehicle, while Deputy Scott, the dependent, was the lead police officer pursuing him. During the course of the pursuit, police officers made several events to stop Harris, however, the chase came to an end when Deputy Scott deliberately crashed his police car into Harris’ vehicle, resulting in severe injuries and left Harris quadriplegic in a wheelchair.
Victor Harris was traveling at seventy-three miles per hour in a fifty-five mile-per-hour zone on a two-lane highway in Georgia. Harris continued to accelerate and fled when a police officer activated the cruiser's overhead lights and pursued him. A line of police cruisers chased after Harris, with Deputy Scot in the lead. Six minutes, and nearly ten miles into the chase, Deputy Scott radioed his supervisor for permission to bump Harris's car to make it spin. The supervisor approved, and Deputy Scott proceeded to bump Harris's car. Rather than spinning to a halt, Harris's car skidded out of control, flipped, and rolled over. Harris survived but was left in a quadrangle. Scott's cruiser was equipped with a video camera that captured the entire incident.
Harris filed a federal lawsuit against Deputy Scott, claiming that the excessive use force infringed upon his Fourth Amendment rights. The case proceeded through the District Court and the Court of Appeals before reaching up to Supreme Court, which granted the petition for certiorari in order to determine whether Deputy Scott’s actions were justified under the circumstances.
Through the course of history, law enforcement has faced a great deal of criticism surrounding the use of physical force by police officers. From the earliest days of the profession up to current practices, the use of force has been a fundamental element of law enforcement as part of their job. Training programs provide law enforcement officers with necessary legal and ethical knowledge, as well as the practical skills to effectively manage situations that require force.
In the legal case of Scott v. Harris, the Court of Justice was presented with the questions of whether the excessive of force by an officer during a high-speed pursuit, resulting in severe injuries, violated the Fourth Amendment’s prohibition against unreasonable seizures. The Court also had to consider whether Deputy Scott was entitled to qualified immunity, a legal protection granted to government officials when their actions do not violate a constitutional right.
Relevant Supreme Court Cases: Tennessee v. Garner
Throughout the case, the Supreme Court examined several issues and referred to relevant precedents, including Tennessee v. Garner. This legal case addressed the use of force by police officers during arrest and ultimately determined that deadly force should only be used in situations where it is necessary to prevent death or serious injury to themselves or another person. In Scott v. Harris, the Court relied on the analysis from Tennessee v. Garner and utilized the "totality of the circumstances" test to determine the reasonableness of Deputy Scott's use of force.
In interpreting the Fourth Amendment, the Court had to consider the balance between the government's interest in capturing fleeing suspects and the individual’s right to be free from excessive force. This case presented a unique question regarding the use of force during high-speed pursuits and raised concerns about safety, law enforcement responsibility, and individual rights. The Court found that the high-speed chase in question posed a significant risk to public safety, as Harris drove at speeds exceeding 85 miles per hour on residential streets.
Precision Intervention Technique (‘PIT’)
During the chase, Harris pulled into the parking lot of a shopping center and was nearly boxed in by the various police vehicles. “Respondent evaded the trap by making a sharp turn,
colliding with Scott’s police car, exiting the parking lot, and speeding off once again down a
two-lane highway” (Justia Law, 2020). Failing to end the high-speed chase, Deputy Scott radioed his supervisor for permission and was told to “go ahead and take him out.” Deputy Scott employed the “Precision Intervention Technique (‘PIT’) maneuver, which resulted in Harris losing control of his vehicle, which left the roadway, ran down an embankment, overturned, and crashed. The decision was deemed necessary to protect the public from harm caused by Harris's reckless driving.
The Supreme Court concluded that Deputy Scott’s actions were justifiable and did not infringe upon the Fourth Amendment. The Court found that the use of force was objectively reasonable given the immediate threat to public safety posed by the high-speed chase. Deputy Scott was granted qualified immunity as his actions did not violate any established constitutional rights at the time of the incident.
While the use of force can be necessary in certain situations, it is crucial that law enforcement officers adhere to the guidelines outlined in the Tennessee v. Garner case when applying force, even when it may be necessary to do so.
The use of police pursuits has a complex history in law enforcement. These tactics are employed to capture suspects who pose an immediate risk to public safety or have committed serious crimes. However, these pursuits have resulted in many injuries and deaths, both to suspects and innocent bystanders. Over the years, several lawsuits have legal challenges to the constitutionality of police pursuits. These cases have questioned whether the police's use of force during pursuits is justified and proportional to the situation.
Ruling of the Case
The Court emphasized that the reasonableness of an officer's actions during a high-speed pursuit should be evaluated based on the totality of the circumstances. According to the pursuits policy, there are three policy models: Discretionary, Restrictive, and Discouraging. Discretionary allows officers to make all major decisions relating to initiation, tactics, and termination. Restrictive places certain restrictions on officers' judgments and decisions. Discouraging means severely cautioning against or discouraging any pursuit, except in the most extreme circumstances (Thompson, 2005). It also says they can pursue if officers see offenses that pose such a danger to the public that they outweigh the hazards of pursuing the fleeing vehicle.
In this case, the court ruling in Scott v. Harris highlights the importance of proper law enforcement practices in high-speed chases. Video evidence played a key role in the decision, clearly showing the danger of Harris's driving and justifying Scott's decision to use force to end the pursuit.
Implication of the Decision
This ruling in Scott v. Harris has significant implications for law enforcement agencies, providing guidance on the use of force if they reasonably believe that the suspect poses a significant threat to public safety. This has been cited in subsequent cases involving police pursuits, emphasizing the need for proper practices and policies.
According to the National Highway Traffic Safety Administration (NHTSA), fatal crashes involving police pursuits kill more than one person every day; 525 people were killed in 2021, and 545 were killed in 2020. According to Law Enforcement Management and Administrative Statistics (LEMAS) data from 2009 to 2013, 21 percent of those seriously injured in police pursuits are individuals not involved in the pursuit (Pursuit For Change, 2023). Given statistics show the potential risks and challenges associated with high-speed chases, it is crucial to have appropriate practices and policies in place to address these concerns. By doing so, law enforcement agencies can ensure the safety of both officers and the public they serve.
“Today’s police officer is faced with more modern technology than ever before” (Novak et al, 2020). The way evidence is collected in high-speed chase cases has been transformed by technological advancements. Specifically, the use of video recording devices in police cruises has had a significant impact on evidence-gathering practices. The court has emphasized the importance of taking into account these technological advancements when evaluating the admissibility of scientific evidence.
Videotape Evidence
The high-speed chase incident was captured on the vehicle of Deputy Scott’s dashboard camera. The issue in the case is whether or not the video footage can be relied upon as evidence. However, there are no allegations or indications that the videotape was tampered with or altered in any way. Therefore, it can be considered a trustworthy and precise representation of the events that took place. “The Court of Appeals adopted respondent’s assertions that, during the chase, “there was little, if any, actual threat to pedestrians or other motorists, as the roads were mostly empty and [respondent] remained in control of his vehicle” (Justia Law, 2020). They pointed out that the video did not show the entire chase, and that the absence of certain details raised questions about its reliability.
The Supreme Court, however, ruled that the video could be considered reliable evidence in legal proceedings. The court relied heavily on the precedent set in White v. United States, 495 U.S. 575 (1990), which established that video evidence can be used as long as it is authentic and relevant to the case. It was emphasized that the video must be evaluated in the context of other evidence presented. Despite some gaps in the footage, the court found it to be a sufficient and accurate representation of the chase.
In reaching this conclusion, the court relied on video evidence of the pursuit, which showed that Harris was driving at extremely high speeds and posing a serious threat to public safety. The case signifies a reminder that videotape evidence can be a valuable tool in legal proceedings. However, it is important to assess the reliability of the footage to weigh it against the other evidence to ensure a comprehensive understanding of the events in question.
Conclusion
Scott v. Harris has had a significant impact on Fourth Amendment jurisprudence. Its ruling established a framework for evaluating the use of force during high-speed pursuits, clarifying the boundaries of law enforcement's authority. Additionally, the case provided guidance to lower courts in similar situations involving the use of force during police pursuits.
The Supreme Court's decision in Scott v. Harris (2007) recognized the changing nature of technology and its impact on legal cases. Specifically, the video footage of the pursuit and crash played a crucial role in the court's determination of reasonableness. The video provided a clear visual account of the events, allowing the court to evaluate the police's actions and decide whether the use of force was justified.
In summary, Scott v. Harris set a precedent for the use of reasonable force, including deadly force, in pursuits to prevent death or serious injury. The case also underscored the importance of technology in evidence-gathering and its impact on shaping legal outcomes.
References
admin. (2023, September 25). Sometimes Screams Are Heard | Pursuit For Change. https://pursuitforchange.org/voices-of-victims/sometimes-your-screams-are-heard/
Novak, K. J., Cordner, G. W., & Roberg, R. R. (2020). Police & society. Oxford University Press.
Restrictive Policies for High-Speed Police Pursuits | Office of Justice Programs. (n.d.). Www.ojp.gov. https://www.ojp.gov/ncjrs/virtual-library/abstracts/restrictive-policies-high-speed-police-pursuits
Scott v. Harris, 550 U.S. 372 (2007). (2020). Justia Law. https://supreme.justia.com/cases/federal/us/550/372/
Scott v. Harris Case Brief Summary | Law Case Explained. (n.d.). Www.youtube.com.
Retrieved November 27, 2023, from
https://www.youtube.com/watch?v=69F6aI9B6EQ&t=25s
Thompson, J. (2005). Police Pursuits: Are No-Pursuit Policies The Answer? https://www.cji.edu/wp-content/uploads/2019/04/police_pursuits.pdf