Matthew Reid Hinson v. R. A. Bias, et al.
FourthAmendment Privacy
Did the Eleventh Circuit exceed its limited jurisdiction when, on appeal from a denial of summary judgment in a qualified-immunity case, it vacated the district court's order based on its factual disagreement with the district court's review of a surveillance video?
QUESTION PRESENTED The Courts of Appeals have jurisdiction to hear appeals from final decisions issued by district courts. See 28 U.S.C. § 1291. A narrow exception exists for “collateral orders” that do not end the litigation but effectively amount to final decisions on issues that can be separated from the central issues that remain to be tried. The denial of summary judgment in a qualifiedimmunity case is such a collateral order—but only with respect to the legal issues decided by the district court in its qualified-immunity analysis. As this Court has explained, the limited appellate jurisdiction to review those orders does not extend to the “portion of a district court’s summary judgment order that, though entered in a ‘qualified immunity’ case, determines only a question of ‘evidence sufficiency,’ i.e., which facts a party may, or may not, be able to prove at trial.” Johnson v. Jones, 515 U.S. 304, 313 (1995) (emphasis added). In this case, the Eleventh Circuit vacated a district court order denying summary judgment based only on its disagreement with the district court’s review of the factual the district court’s conclusion that a surveillance video tape would allow a reasonable juror to conclude that petitioner Matthew Hinson was not resisting arrest. The question presented is: Did the Eleventh Circuit exceed its limited jurisdiction when, on appeal from a denial of summary judgment in a qualified-immunity case, it vacated the district court’s order based on its factual disagreement with the district court’s review of a surveillance video?