## Facts

- Deputies in Sacramento County encountered a motorcycle driven by Brian Willard with Philip Lewis as a passenger.
- After deputies signaled the motorcycle to stop, Willard fled, and Deputy James Smith initiated a high-speed pursuit.
- The chase lasted about 75 seconds over roughly 1.3 miles through a residential area, reaching speeds near 100 mph and forcing other road users to evade the motorcycle.
- Willard lost control while turning; the motorcycle fell.
- Smith braked but skidded and struck Philip Lewis, causing fatal injuries.
- Lewis’s parents, as representatives of his estate, sued under 42 U.S.C. § 1983, alleging violations of the Fourth Amendment and Fourteenth Amendment substantive due process.
- The district court granted summary judgment for the defendants; the Ninth Circuit reversed on the Fourteenth Amendment theory using a deliberate-indifference/reckless-disregard standard.

## Issues

1. Whether an officer’s unintentional killing of a fleeing suspect’s passenger during a high-speed pursuit constitutes a Fourth Amendment “seizure.”
2. If the Fourth Amendment does not apply, what culpability standard governs a Fourteenth Amendment substantive due process claim arising from a high-speed police chase.
3. Whether the officer’s conduct in this pursuit met the constitutional standard for executive action that “shocks the conscience.”

## Decision

- The Supreme Court reversed the Ninth Circuit and reinstated judgment for the defendants.
- The Court held there was no Fourth Amendment seizure because the fatal impact was not a termination of freedom of movement through means intentionally applied.
- The Court held substantive due process was not violated where the officer lacked a purpose to cause harm unrelated to the legitimate objective of arrest.
- The Court rejected “deliberate indifference” or “reckless disregard” as sufficient for substantive due process liability in the context of a fast-developing high-speed pursuit.

## Legal Principles

- When a specific constitutional provision governs a claim, courts analyze under that provision rather than substantive due process; but the Fourth Amendment applies only if a “seizure” occurred.
- A Fourth Amendment seizure requires intentional acquisition of control; unintended injury during pursuit is not a seizure absent intentional means applied to restrain.
- Substantive due process limits executive action only for conduct that is so arbitrary and egregious that it “shocks the conscience.”
- The “shocks the conscience” inquiry is context-dependent: where officials must make split-second decisions, liability generally requires intent to harm rather than lesser fault.
- In high-speed chases aimed at apprehension, a substantive due process violation requires a purpose to cause harm unrelated to the legitimate object of arrest.

## Conclusion

The Court held that an accidental fatality during a high-speed police pursuit is not a Fourth Amendment seizure and that, under substantive due process, only a purpose to cause harm unrelated to lawful arrest objectives can satisfy the conscience-shocking standard for § 1983 liability in this setting.


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