Plumhoff v. Rickard, 134 S. Ct. 2012

Rickard led a high-speed pursuit in an unmarked white Honda with a passenger; pursuit involved speeds over 100 mph and multiple traffic hazards.
The chase ended when Rickard’s car spun into a parking lot, collided with a cruiser, and Rickard attempted to reverse and flee.
Officers fired 3 shots, then 12 more shots as Rickard resumed fleeing, killing Rickard and the passenger.
Rickard’s daughter, as a §1983 plaintiff, alleged excessive force under the Fourth and Fourteenth Amendments.
District Court denied summary judgment on qualified immunity; the Sixth Circuit affirmed the denial on the merits, while addressing appellate jurisdiction issues.
The Supreme Court reversed, holding officers did not violate the Fourth Amendment and that qualified immunity would bar relief even if a violation were found.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Sixth Circuit properly had jurisdiction to hear the appeal	Rickard argues appellate review is proper under collateral-order doctrine	Plumhoff contends Johnson precludes immediate appeal	Yes; jurisdiction proper under §1291 for qualified-immunity-based appellate review
Whether officers violated the Fourth Amendment by using deadly force	Rickard contends deadly force was unlawful and excessive	Officers assert force was reasonable to end the dangerous chase	No Fourth Amendment violation; force reasonable under totality of circumstances
If a violation occurred, whether it was clearly established at the time	Rickard asserts a clearly established standard prohibiting such use of force	No clearly established law forbade the conduct at issue	Even if violation occurred, qualified immunity applies because law was not clearly established

Scott v. Harris, 550 U.S. 372 (2007) (precedent on appellate review of factual determinations in qualified-immunity cases; used to justify jurisdictional stance)
Johnson v. Jones, 515 U.S. 304 (1995) (immediary appealability of non-final orders; facts-only issue not appealable)
Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity—court discretion to decide sequence of questions)
Graham v. Connor, 490 U.S. 386 (1989) (objective reasonableness standard in excessive-force claims)
Mitchell v. Forsyth, 472 U.S. 511 (1985) (establishes immunity as a pre-trial issue and relation to final judgment)
Alderman v. United States, 394 U.S. 165 (1969) (personal Fourth Amendment rights; no vicarious liability for passengers)
Brosseau v. Haugen, 543 U.S. 194 (2004) (no clearly established law precluded officer’s action as of 1999; facts depend on case)
Saucier v. Katz, 533 U.S. 194 (2001) (initial two-step framework for qualified immunity (now modified))
County of Sacramento v. Lewis, 523 U.S. 833 (1998) (high-speed pursuit and due-process considerations)