Tolan v. Cotton

When ruling on a motion for summary judgment in cases dealing with qualified immunity, courts must weigh the evidence and all justifiable inferences in the nonmoving party’s favor.

Respondent, arriving at Petitioner’s home, had responded to a call for assistance when the other officer mistakenly thought he had located a stolen car. While the other officer was detaining Petitioner, Respondent forcefully escorted Petitioner’s mother against a wall possibly causing her to fall, at which time Petitioner rose from the ground and yelled at Respondent to “[g]et your fucking hands off my mom.” Respondent drew his weapon and fired three shots into Petitioner.

Petitioner suited filed suit against Respondent claim that his excessive use of force violated Petitioner’s Forth Amendment rights. Based on the doctrine of qualified immunity, the district court granted summary judgment for Respondent and the Court of Appeals for the Fifth Circuit affirmed on the basis that Respondent’s action did not violate any clearly established rights.

The Supreme Court vacated the lower courts’ ruling and remanded, holding that the Fifth Circuit did not correctly weigh the evidence when affirming the summary judgment. The Court stated that the court below impermissibly gave credit to evidence that supported the moving party while ignoring evidence offered by the opposing party. The case is remanded to determine the correct weight that should be given to Petitioner’s evidence.