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Lytle v. Bexar County, Texas

560 F.3d 404 (2009)

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Lytle v. Bexar County, Texas

United States Court of Appeals for the Fifth Circuit
560 F.3d 404 (2009)

Facts

Sheriff’s Deputy Robert O’Donnell (defendant) attempted to pull over a Ford Taurus in which Heather Lytle (plaintiff) was a passenger. The driver was suspected of having stolen the Taurus. When Deputy O’Donnell turned his emergency lights on, the driver failed to yield, and a high-speed chase ensued. At one point, the driver collided with an oncoming vehicle and came to a temporary stop. At this point, Deputy O’Donnell exited his police cruiser and the Taurus began moving in reverse toward Deputy O’Donnell before pulling forward again to flee. As the Taurus went forward, Deputy O’Donnell fired two shots into the Taurus, striking and killing Lytle. Her family brought suit individually, and on her behalf, claiming that Deputy O’Donnell had used excessive force that violated Lytle’s Fourth Amendment right to be free from unreasonable seizure. Deputy O’Donnell argued that his use of force was reasonable given the threat of harm the Taurus posed to himself and the public generally. Deputy O’Donnell moved to dismiss the suit based on qualified immunity. The district court denied his motion, and Deputy O’Donnell entered an interlocutory appeal to the United States Court of Appeals for the Fifth Circuit.

Rule of Law

Issue

Holding and Reasoning (Prado, J.)

Dissent (Smith, J.)

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