Saucier v. Katz

Saucier v. Katz, 533 U.S. 194 (2001), was a United States Supreme Court case in which the Court considered the qualified immunity of a police officer to a civil rights case brought through a Bivens action.

Saucier v. Katz
Argued March 20, 2001
Decided June 18, 2001
Full case nameDonald Saucier, Petitioner v. Elliot M. Katz and In Defense Of Animals
Citations533 U.S. 194 (more)
121 S. Ct. 2151; 150 L. Ed. 2d 272; 2001 U.S. LEXIS 4664; 69 U.S.L.W. 4481; 2001 Cal. Daily Op. Service 5000; 2001 Daily Journal DAR 6137; 2001 Colo. J. C.A.R. 3134; 14 Fla. L. Weekly Fed. S 361
ArgumentOral argument
Case history
PriorCertiorari to the United States Court of Appeals for the Ninth Circuit
Holding
A qualified immunity ruling requires an analysis not susceptible of fusion with the question whether unreasonable force was used in making the arrest.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityKennedy, joined by Rehnquist, O'Connor, Scalia, Thomas; Souter (parts I, II)
ConcurrenceGinsburg, joined by Stevens, Breyer
Concur/dissentSouter
Laws applied
U.S. Const. amend. IV
Overruled by
Pearson v. Callahan, 555 U.S. 223 (2009)

Background

In 1994, the Presidio Army Base in San Francisco, California was the site of an event to celebrate conversion of the base to a national park. Elliot Katz, the president of a group called In Defense of Animals, brought with him a cloth banner, approximately 4 by 3 ft, that read "Please Keep Animal Torture Out of Our National Parks," to voice opposition to the possibility that the Letterman Army Hospital might be used for experiments on animals.

While Vice President Albert Gore, Jr. began giving a speech, Katz removed the banner from his jacket, started to unfold it, and walked toward the fence and speakers' platform. Petitioner Donald Saucier, a military police officer on duty that day, had been warned by his superiors of the possibility of demonstrations, and respondent had been identified as a potential protester. He and Sergeant Steven Parker, another military police officer, moved to intercept Katz as he walked toward the fence. As Katz reached the barrier and began placing the banner on the other side, the officers grabbed respondent from behind, took the banner, and rushed him out of the area. Saucier and Parker took respondent to a nearby military van, where, respondent claims, he was shoved or thrown inside.

Katz brought an action in the United States District Court for the Northern District of California against petitioner and other officials pursuant to Bivens v. Six Unknown Named Agents,[1] alleging that defendants had violated his Fourth Amendment rights by using excessive force to arrest him.

Decision

The Supreme Court in an opinion delivered by Justice Kennedy held that Saucier was entitled to qualified immunity.[2]

The Supreme Court held that qualified immunity analysis must proceed in two steps. A court must first ask whether "the facts alleged show the officer’s conduct violated a constitutional right." Then, if a constitutional right was violated, the court would go on to determine whether the constitutional right was "clearly established."[3]

In its 2009 decision in Pearson v. Callahan[4] the Supreme Court modified the two-step immunity analysis imposed in Saucier to make its application less restrictive. Saucier required courts to confront the first prong of the analysis before they move on to the second, but Pearson says "the Saucier protocol should not be regarded as mandatory in all cases."

Pearson goes on to say, "Our decision does not prevent the lower courts from following the Saucier procedure; it simply recognizes that those courts should have the discretion to decide whether that procedure is worthwhile in particular cases."

See also

References
  1. Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971).
  2. Saucier v. Katz, 533 U.S. 194 (2001).
  3. Saucier, 533 U.S. at 201.
  4. Pearson v. Callahan, 555 U.S. 223 (2009).

Further reading
  • Sampsell-Jones, Ted (2007). "Reviving Saucier: Prospective Interpretations of Criminal Laws" (PDF). George Mason Law Review. 14: 725.
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