In its recent ruling the U.S. Supreme Court (SCOTUS) held that a New Mexico State Police Officer who shot and killed a man who pointed a gun at law enforcement from inside his home benefits from qualified immunity. Qualified immunity protects government officials from lawsuits alleging a violation of rights. Lawsuits of this kind are only allowed when officials violate a “clearly established” constitutional or statutory right. When deciding whether or not a violation occurred, courts consider if a reasonable official would have known the defendant’s conduct violated the individual’s rights. When a court dives into this analysis, it applies the law that was in place at the time of the alleged violation.
Details of the Case
White was the final officer who arrived at the residence of Samuel and Daniel Pauly, who were brothers. According to the case facts, two other law enforcement officers had already arrived to speak with Daniel Pauly after reports of erratic driving. These officers approached the home – according to the SCOTUS – in a covert manner. When the brothers asked who was outside, the officers identified themselves but the brothers did not hear the warning. When White arrived, he heard one brother state they had guns. One brother stepped out of the home’s back door and fired two shotgun blasts while screaming; the other brother opened one of the home’s front windows and pointed a handgun in White’s direction. Another officer fired but missed, while White fatally shot Samuel Pauly.
The lawsuit alleged the three police officers violated the Pauly brothers’ Fourth Amendment right to be free from excessive force.The SCOTUS considered only White’s case. In its opinion, his situation was different than the other officers because he faced a suspect pointing a firearm in his direction.
The Court’s Opinion
The case, White v. Pauly, vacates the 10th Circuit’s lower decision that an officer in White’s position would have believed under clearly established law that a warning shot was required prior to firing off his gun. The SCOTUS held the lower court misunderstood the legal analysis.
The SCOTUS held the police officer did not violate clearly established law on the record, as described by the panel for the lower court. The 10th Circuit Court of Appeals, according to the opinion, relied on too high a level of generality instead of taking into consideration the particular facts and circumstances of the case at hand.