## Facts

- Houston Jones, a diabetic, suffered an insulin seizure on a street; police officers mistakenly believed he was intoxicated, arrested him, and took him to a Chicago police station.
- Jones later awoke in a hospital with several broken ribs and claimed officers used excessive force during the arrest and later at the station.
- Jones filed a 42 U.S.C. § 1983 action against five named officers for excessive force.
- Three officers moved for summary judgment on qualified immunity, asserting there was no evidence they beat Jones or were present when others allegedly did.
- Jones relied on (1) his deposition testimony that officers used excessive force during the arrest and in the booking area, and (2) the officers’ depositions admitting they were present at the arrest and in or near the booking area while Jones was there.
- The district court found sufficient circumstantial evidence to create a triable issue regarding the officers’ involvement or presence and denied summary judgment.

## Issues

1. Whether a defendant public official may take an immediate interlocutory appeal from a denial of qualified-immunity summary judgment insofar as the order turns on whether the record raises a “genuine” issue of material fact (evidentiary sufficiency), rather than a purely legal question.

## Decision

- The Supreme Court affirmed the dismissal of the interlocutory appeal for lack of appellate jurisdiction.
- A denial of qualified-immunity summary judgment is not immediately appealable under 28 U.S.C. § 1291 to the extent it rests on the district court’s determination that the evidence is sufficient to create a genuine issue of fact for trial.
- Immediate appeal remains available only for the purely legal question whether, taking the facts as assumed by the district court, the conduct violates clearly established law.

## Legal Principles

- Under the final-judgment rule (28 U.S.C. § 1291), appellate jurisdiction generally extends only to “final decisions,” with limited exceptions.
- The collateral order doctrine permits immediate appeal only for orders that conclusively resolve an important issue separate from the merits and that would be effectively unreviewable after final judgment.
- Qualified-immunity interlocutory review is available for legal questions (e.g., whether assumed facts show a violation of clearly established law), but not for fact-related disputes about what the record could prove at trial.
- A defendant may not use qualified immunity to obtain immediate appellate review of a district court’s Rule 56 determination that the evidence creates a genuine dispute of material fact; such sufficiency challenges can be reviewed after final judgment.

## Conclusion

The Court held that officials asserting qualified immunity cannot immediately appeal a summary-judgment denial that turns on evidentiary sufficiency and disputed facts; interlocutory review is limited to legal questions about clearly established law based on the facts assumed by the district court.


Johnson v. Jones, 515 U.S. 304 (1995)