510 U.S. 510 (1994), 92-8579, Elder v. Holloway
|Docket Nº:||Case No. 92-8579|
|Citation:||510 U.S. 510, 114 S.Ct. 1019, 127 L.Ed.2d 344, 62 U.S.L.W. 4149|
|Party Name:||ELDER v. HOLLOWAY et al.|
|Case Date:||February 23, 1994|
|Court:||United States Supreme Court|
Argued January 10, 1994
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
Petitioner Elder was arrested without a warrant after respondents, Idaho police officers, surrounded his house and ordered him to come out. Alleging that the arrest violated his Fourth Amendment right to be secure against unreasonable seizure, Elder sued the officers for damages under 42 U.S.C. § 1983. The officers raised the defense of qualified immunity, which shields public officials from actions for damages unless their conduct was unreasonable in light of clearly established law. The District Court found the law clear that, absent exigent circumstances, a warrant would have been required had the arrest occurred inside the house. The court found it unclear, however, whether a warrant was needed when officers surrounded a house and requested an individual to come out and surrender. Finding no controlling state or Ninth Circuit case law, the court granted summary judgment for respondents. On appeal, the Court of Appeals noticed Ninth Circuit precedent in point missed in the District Court. United States v. Al-Azzawy, 784 F.2d 890, the Court of Appeals thought, might have alerted a reasonable officer to the constitutional implications of putting a suspect under arrest outside a surrounded house. The court held, however, that the Al-Azzawy decision could not be used to Elder's advantage. Although typing the qualified immunity inquiry a pure question of law, the court read this Court's decision in Davis v. Scherer, 468 U.S. 183, to require plaintiffs to present to the district court, as "legal facts," the cases showing that the right asserted was clearly established. Just as appellants forfeit facts not presented to the court of first instance, the Court of Appeals reasoned, so, in the peculiar context of civil rights qualified immunity litigation, a plaintiff may not benefit on appeal from a precedent neither he nor the district court itself mentioned in the first instance.
Appellate review of qualified immunity dispositions must be conducted in light of all relevant precedents, not simply those cited to, or discovered by, the district court. The rule declared by the Court of Appeals in this case does not aid the qualified immunity doctrine's central objectiveto protect public officials from undue interference with their duties and from potentially disabling threats of liabilitybecause its operation is unpredictable in advance of the district court's adjudication. Nor does the rule further the interest in deterring public officials'
unlawful actions and compensating victims of such conduct. Instead, it simply releases defendants because of shortages in counsels' or the court's legal research or briefing. The decision in Davis v. Scherer, supra, was misconstrued by the Court of Appeals. Davis did not concern what authorities a court may consider in determining qualified immunity. The Court held in Davis only this: To defeat qualified immunity, the federal right on which the claim for relief is basedrather than some other rightmust be clearly established. Whether a federal right was clearly established at a particular time is a question of law, not "legal facts," and must be resolved de novo on appeal. A court of appeals reviewing a qualified immunity judgment should therefore use its full knowledge of its own and other relevant precedents. It is left to the Court of Appeals to consider, in light of all relevant authority, including Al-Azzawy, whether respondents are entitled to prevail on their qualified immunity defense. Pp. 514-516.
975 F.2d 1388, reversed and remanded.
Michael E. Tankersley argued the cause for petitioner. With him on the briefs were Brian Wolfman, Alan B. Morrison, and John C. Lynn, appointed by this Court, 510 U.S. 806.
James J. Davis argued the cause and filed a brief for respondents.[*]
Justice Ginsburg delivered the opinion of the Court.
This case presents the question whether an appellate court, reviewing a judgment according public officials qualified
immunity from a damages suit charging violation of a federal right, must disregard relevant legal authority not presented to, or considered by, the court of first instance. We hold that appellate review of qualified immunity dispositions is to be conducted in light of all relevant precedents, not simply those cited to, or discovered by, the district court.
In April 1987, police officers in Idaho learned that Charles Elder was wanted by Florida authorities. They set out to arrest Elder, but did not obtain an Idaho arrest warrant. The officers planned to apprehend Elder at his workplace, in a public area where a warrant is not required. See United States v. Watson, 423 U.S. 411, 418, n. 6 (1976). Finding that Elder had already left his jobsite, the officers surrounded the house in which he resided and ordered him to come out. Elder suffered epileptic seizures during the episode, and an officer instructed him to crawl out of the house to avoid injury from falling. Elder, instead, walked through the doorway, immediately suffered another seizure, and fell on the concrete walk in front of the house. He sustained serious brain trauma and remains partially paralyzed.
Alleging that the warrantless arrest violated his Fourth Amendment right to be secure against unreasonable seizure, Elder sued the arresting officers for damages under 42 U.S.C. § 1983. The doctrine of qualified immunity shields public officials like respondents from damages actions unless their conduct was unreasonable in light of clearly established law. The District Court analyzed Elder's case in three steps. Had the arrest occurred inside the house, that court recognized, clear law...
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