Summary
The United States Supreme Court held that a public official asserting qualified immunity may not immediately appeal a district court's summary judgment order to the extent the order determines only whether the pretrial record presents a genuine issue of fact. The Court distinguished immediately appealable legal questions concerning clearly established law from unreviewable fact-sufficiency determinations. The Court affirmed the Seventh Circuit's dismissal of the interlocutory appeal.
Topics
Practice areas
Questions Presented
- Whether a defendant asserting qualified immunity may immediately appeal a district court's denial of summary judgment insofar as the order determines only whether the pretrial evidence is sufficient to create a genuine issue of fact.
- Whether the Seventh Circuit correctly dismissed the officers' interlocutory appeal for lack of jurisdiction over their evidence-sufficiency challenge.
Holdings
- A defendant entitled to invoke qualified immunity may not immediately appeal a district court's summary judgment order insofar as the order determines whether the pretrial record presents a genuine issue of fact for trial.
Key quotations
“We hold that the defendants cannot immediately appeal this kind of fact-related district court determination.” (515 U.S. at 305)
“This kind of order, we conclude, is not appealable.” (515 U.S. at 313)
“For these reasons, we hold that a defendant, entitled to invoke a qualified immunity defense, may not appeal a district court's summary judgment order insofar as that order determines whether or not the pretrial record sets forth a "genuine" issue of fact for trial.” (515 U.S. at 320)
Factual background
Houston Jones, a diabetic, suffered an insulin seizure on the street. Police officers mistakenly believed he was intoxicated, arrested him, and transported him to a police station; Jones later awoke in a hospital with several broken ribs. Jones alleged that the officers used excessive force during the arrest and beat him at the station. Three officers denied that the evidence showed they participated in or observed the alleged beating, but their depositions established that they were present at the arrest and in or near the booking room.
Procedural history
Jones brought a § 1983 action against five police officers, alleging excessive force and beating. Three officers moved for summary judgment, arguing that the record contained no evidence that they participated in or witnessed the beating. The district court denied the motion, finding sufficient circumstantial evidence to create a genuine issue of fact. The Seventh Circuit dismissed the officers' appeal, and the Supreme Court affirmed.