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Jefferson v. Lias

3rd Circuit

December 16, 2021

After a high-speed chase, a police officer shot the fleeing motorist. That motorist filed a Section 1983 action against the police officer for violating his Fourth Amendment rights and a Monell claim against the municipality that employed the officer for failure to adequately train. The District Court determined that the officer was entitled to qualified immunity and that the defendant suffered no constitutional injury, leaving no basis for his Monell claim. The Third Circuit reversed. First, the Court held that a jury could find that the officer was not in danger of being struck by the plaintiff’s car and that the officer’s decision to shoot through the plaintiff’s driver’s side window was not justified by an objective threat that the plaintiff posed to him or others in the area. The Third Circuit then held that the plaintiff’s alleged constitutional right was clearly established, in large part based on the Third Circuit’s decision in Abraham v. Raso as well as a survey of other circuit courts of appeal. Lastly, the Third Circuit held that under Heck v. Humphries, the plaintiff’s criminal conviction that arose out of the high-speed chase did not preclude the present civil action. The concurring opinion is noteworthy for its willingness to rule that “there is a growing consensus that it is simply unreasonable for officers to shoot at fleeing suspects.”

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