County of Sacramento v. Lewis

What This Case Is About

County of Sacramento v. Lewis is a landmark Supreme Court decision that establishes the standard for substantive due process claims arising from high-speed police pursuits. The Court held that in the context of a high-speed chase, only conduct that “shocks the conscience” — meaning conduct undertaken with a purpose to cause harm unrelated to legitimate law enforcement — violates the Fourteenth Amendment. Mere deliberate indifference or reckless disregard for life is not enough.

The Facts

Sheriff’s Deputy James Smith responded to a call and encountered a motorcycle traveling at high speed, driven by Brian Willard with Philip Lewis as a passenger. Deputy Stapp, another officer, attempted to stop the motorcycle by activating his lights and yelling for it to stop. When Willard maneuvered between two patrol cars and sped off, Smith immediately activated his emergency lights and siren and began a high-speed pursuit.

The chase covered approximately 1.3 miles in roughly 75 seconds, reaching speeds up to 100 miles per hour. The pursuit ended when the motorcycle tipped over. Smith slammed on his brakes, but his patrol car skidded into Lewis, causing massive injuries and death.

Lewis’s family brought a § 1983 action alleging that Smith’s conduct during the chase deprived Lewis of his Fourteenth Amendment right to substantive due process. The district court granted summary judgment for Smith, but the Ninth Circuit reversed, holding that deliberate indifference was the appropriate standard.

What the Court Decided

The Supreme Court reversed the Ninth Circuit and held that Smith did not violate substantive due process.

The Fourth Amendment does not apply. The Court first addressed whether the Fourth Amendment — which governs seizures — applied to the case. It held that the Fourth Amendment covers only intentional seizures, and Smith did not intentionally seize Lewis. The motorcycle crash was not an intentional application of force to terminate Lewis’s movement. Therefore, the claim had to be analyzed under the Fourteenth Amendment’s substantive due process clause.

The “shocks the conscience” test governs. The Court held that the touchstone of substantive due process is protection against government conduct that “shocks the conscience.” This standard requires more than negligence (which is never enough) and more than even deliberate indifference.

Context matters for the conscience-shocking standard. The Court distinguished between different contexts:

• In custodial settings (like prisons), where officials have time to deliberate, “deliberate indifference” to known risks can shock the conscience.
• In high-speed pursuit situations, where officers must make split-second decisions under extreme pressure, only a “purpose to cause harm unrelated to the legitimate object of arrest” rises to the conscience-shocking level.

Because there was no evidence that Smith intended to harm Lewis — he was trying to apprehend a fleeing motorcyclist — his conduct did not violate substantive due process, even though it was reckless.

Why This Case Matters for Your § 1983 Case

County of Sacramento v. Lewis is essential for understanding when police conduct during pursuits and emergencies can give rise to § 1983 liability:

• High-speed chases require “intent to harm.” If your claim arises from a police chase, you must show the officer had a purpose to cause harm unrelated to legitimate law enforcement. Recklessness alone is not enough.

• The Fourth Amendment requires an intentional seizure. If an officer did not intentionally apply force to stop you, the Fourth Amendment does not apply, and you must rely on the more demanding substantive due process standard.

• Context determines the standard. The level of culpability required to “shock the conscience” varies by context. In situations requiring split-second decisions, the bar is very high. In custodial settings where officials have time to reflect, the bar is lower.

• Negligence is never enough. No matter the context, mere negligence cannot support a substantive due process claim under § 1983.

Key Takeaway

County of Sacramento v. Lewis sets a very high bar for § 1983 claims arising from high-speed police pursuits. Unless you can show that the officer had a purpose to cause harm unrelated to catching the fleeing suspect — not just recklessness or even deliberate indifference — the claim will fail. This “shocks the conscience” standard reflects the Court’s recognition that officers in pursuit situations face extreme time pressure and cannot be held liable for split-second judgments that turn out badly.