Tolan v. Cotton (2013)
- Docket
- 13-551
- Decided
- 2013-01-01
Summary
Question: Should a court consider the factual reasonableness of the search or seizure when applying the "clearly established right" prong of the qualified immunity test in Fourth Amendment cases? Conclusion: Not answered. In a per curiam opinion, the Court held that the Court of Appeals erred in its application of the summary judgment standard by failing to consider all of the evidence in the light most favorable to Tolan. The Supreme Court cited testimony that indicated that the Court of Appeals improperly resolved disputed facts in favor of Cotton. The Court vacated the judgment and remanded the proceeding, with instructions to acknowledge and credit evidence in Tolan's favor when determining whether Cotton's actions violated clearly-established law. Justice Samuel A. Alito, Jr. wrote an opinion concurring in the judgment in which he argued that the Court should avoid granting certiorari to cases that present only a "routine" question of whether the evidence the lower court relied on supported a grant of summary judgment. Justice Antonin Scalia joined in the opinion concurring in the judgment.