Jefferson v. Lias, No. 20-2526 (3d Cir. 2021)
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Officer Staffer saw Jefferson traveling at high speed with his car alarm blaring. Staffer, suspecting the vehicle was stolen, attempted a traffic stop. Jefferson was driving with an open container of alcohol. Fearing a probation violation, Jefferson did not stop. Officer Lias joined the pursuit after hearing radio dispatches, only aware that Jefferson was driving a possibly stolen vehicle. Although other officers observed Jefferson traveling at high speeds, running red lights, ignoring police signals to pull over, and driving close to other vehicles, Lias did not personally witness Jefferson doing so. Jefferson hit a fire hydrant. Officers surrounded Jefferson’s vehicle. Jefferson reversed, striking a police vehicle before backing into an intersection. Lias arrived as Jefferson was driving away. Lias claims that he discharged his firearm because he feared for his own safety and others around him. Jefferson was struck in his forearm, fracturing his bones, but drove away. Jefferson later pled guilty to second-degree eluding.
The district court rejected Jefferson’s 42 U.S.C. 1983 suit, finding Lias entitled to qualified immunity. The Third Circuit reversed. A jury should make factual determinations regarding Lias’s decision to employ deadly force against Jefferson. Video footage makes clear that neither Lias nor anyone else was in danger of being struck by Jefferson. It is clearly established that an otherwise non-threatening individual engaged in vehicular flight is entitled to be free from being subjected to deadly force if it is unreasonable for an officer to believe his or others’ lives are in immediate jeopardy. Jefferson’s second-degree eluding conviction does not preclude his excessive force claim.
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