| Plumhoff v. Rickard | |
|---|---|
 | |
| Argued March 4, 2014 Decided May 27, 2014 | |
| Full case name | Officer Vance Plumhoff, et al., petitioners v. Whitne Rickard, a minor child, individually, and as surviving daughter of Donald Rickard, deceased, by and through her mother, Samantha Rickard, as parent and next friend |
| Docket no. | 12-1117 |
| Citations | 572 U.S. 765 (more) 134 S. Ct. 2012; 188 L. Ed. 2d 1056 |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | Motion for summary judgment denied, Nos. 05-2489/2585, 2011 WL 197426 (W.D. Tenn. Jan. 20, 2011); affirmed, 509 Fed. Appx. 388 (6th Cir. 2012).; cert. granted, 571 U. S. 1020 (2013). |
| Holding | |
| (1) The Sixth Circuit properly exercised jurisdiction under 28 U. S. C. §1291. (2) The officers' conduct did not violate the Fourth Amendment. (3) Even if the officers' conduct had violated the Fourth Amendment, petitioners would still be entitled to summary judgment based on qualified immunity. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Alito, joined by Roberts, Scalia, Kennedy, Thomas, Sotomayor, Kagan; Ginsburg (judgment and Parts I, II, and III–C); Breyer (except Part III–B–2)[a] |
| Laws applied | |
| U.S. Const. amend. IV | |
Plumhoff v. Rickard, 572 U.S. 765 (2014), is a United States Supreme Court case involving the use of force by police officers during high-speed car chases. After first holding that it had jurisdiction to hear the case, the Court held that the conduct of the police officers involved in the case did not violate the Fourth Amendment to the U.S. Constitution, which prohibits unreasonable searches and seizures.
Near midnight on July 18, 2004, Donald Rickard led police officers on a high-speed car chase ending in a parking lot, where officers fired fifteen shots into Rickard's car as he continued to flee. Rickard and his passenger both died from a combination of gunshot wounds and injuries sustained when the car eventually crashed. Rickard's daughter sued the officers who shot Rickard, arguing that they had used excessive force in violation of the Fourth Amendment. The officers moved for summary judgment, arguing they were entitled to qualified immunity because their actions did not violate law that was clearly established at the time of the car chase. The district court denied this motion, and the court of appeals affirmed.
On May 27, 2014, the Supreme Court reversed, holding that the officers did not violate the Fourth Amendment. In a unanimous (9–0) decision authored by Justice Samuel Alito,[a] the Court found that Rickard's actions posed a "grave public safety risk" and that the officers "acted reasonably in using deadly force to end that risk". The Court also found that the number of shots fired was also reasonable, writing that "if police officers are justified in firing at a suspect in order to end a severe threat to public safety, the officers need not stop shooting until the threat has ended". Finally, the Court found that even if the officers' conduct did violate the Fourth Amendment, they would still be entitled to summary judgment based on qualified immunity because their actions did not violate clearly established law at the time of the incident.
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