Charles K. Elder v. R. D. Holloway et al. (510 U.S. 510)
U.S. Supreme Court · decided February 23, 1994 · Supreme Court Database (Spaeth)
- Citation
- 510 U.S. 510 · 114 S. Ct. 1019
- Decided
- February 23, 1994
- Term
- October Term 1993
- Vote
- 9–0
- Majority author
- Justice Ginsburg
- Issue area
- Judicial Power
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Ginsburg delivered the opinion of the Court. This case presents the question whether an appellate court, reviewing a judgment according public officials qualified immunity from a damages suit charging violation of a federal right, must disregard relevant legal authority not presented to, or considered by, the court of first instance. We hold that appellate review of qualified immunity dispositions is to be conducted in light of all relevant precedents, not simply those cited to, or discovered by, the district court. I In April 1987, police officers in Idaho learned that Charles Elder was wanted by Florida authorities. They set out to arrest Elder, but did not obtain an Idaho arrest warrant. The officers planned to apprehend Elder at his workplace, in a public area where a warrant is not required. See United States v. Watson, 423 U. S. 411, 418, n. 6 (1976). Finding that Elder had already left his jobsite, the officers surrounded the house in which he resided and ordered him to come out. Elder suffered epileptic seizures during the episode, and an officer instructed him to crawl out of the house to avoid injury from falling. Elder, instead, walked through the doorway, immediately suffered another seizure, and fell on the concrete walk in front of the house. He sustained serious brain trauma and remains partially paralyzed. II Alleging that the warrantless arrest…
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