County of Sacramento v. Lewis
523 U.S. 833 (1998)

  • Willard and Lewis were on a motorcycle. They were told by the police to pull over, but they fled, leading the police on a high-speed chase that ended with Lewis’ death in a motorcycle crash.
  • Lewis’ family sued the police, and argued that the police chase deprived Lewis of life without affording him procedural due process, as guaranteed by the 14th Amendment.
    • The family argued that the policeman’s deliberate and reckless behavior in pursuing Willard denied Lewis’ constitutional right to not be killed in a motorcycle accident.
  • The Trial Court found for the police. Lewis’ family appealed.
  • The Appellate Court reversed. The police appealed.
  • The US Supreme Court reversed the Appellate Court and found no violation of procedural due process.
    • The US Supreme Court found that only a purpose to cause harm unrelated to the legitimate object of the arrest will shock the conscience, and that is a necessary element for a due process violation.
      • Basically, as long as the police are doing their job, they are not violating due process, even if they act recklessly or if someone is injured.
        • The Court found that it wouldn’t make sense to find that “suspects may ignore a lawful command to stop and then sue for damages sustained in an ensuing chase.”
      • On the other hand, if the police hurt someone for reasons unrelated to police activity (like just beating them for fun), then there could be a procedural due process violation.
  • Basically, the Due Process Clause is there to stop the government from taking arbitrary actions, or to exercise power without any reasonable justification or legitimate government objective. In this case, the police’s actions weren’t arbitrary, and they had a reasonable justification for the police chase (apprehending a potential criminal). Therefore, the police actions met the due process standard.
    • In general, just because an injury might be a civil tort, that doesn’t make it a constitutional violation, there needs to be more.