Willard and Lewis were on a
motorcycle. They were told by the police to pull over, but they fled,
leading the police on a high-speed chase that ended with Lewis' death in a
Lewis' family sued the police,
and argued that the police chase deprived Lewis of life without affording
him procedural due process, as
guaranteed by the 14th Amendment.
The family argued that the
policeman's deliberate and reckless behavior in pursuing Willard denied
Lewis' constitutional right to not be killed in a motorcycle accident.
The Trial Court found for the
police. Lewis' family appealed.
The Appellate Court reversed.
The police appealed.
The US Supreme Court reversed
the Appellate Court and found no violation of procedural due process.
The US Supreme Court found
that only a purpose to cause harm unrelated to the legitimate object of
the arrest will shock the conscience,
and that is a necessary element for a due process violation.
Basically, as long as the
police are doing their job, they are not violating due process, even if they act recklessly or if someone is
The Court found that it
wouldn't make sense to find that "suspects may ignore a lawful
command to stop and then sue for damages sustained in an ensuing
On the other hand, if the
police hurt someone for reasons unrelated to police activity (like just
beating them for fun), then there could be a procedural due process violation.
Basically, the Due Process
Clause is there to stop the government
from taking arbitrary actions, or to exercise power without any reasonable
justification or legitimate government objective. In this case, the
police's actions weren't arbitrary, and they had a reasonable
justification for the police chase (apprehending a potential criminal).
Therefore, the police actions met the due process standard.
In general, just because an
injury might be a civil tort, that doesn't make it a constitutional
violation, there needs to be more.