Victory for Civil Rights Plaintiffs: Supreme Court Reinforces Summary Judgment Standard
Summary judgment is a legal procedural tool that is often used by judges to dispose of cases before they reach a jury. In the context of employment discrimination, many cases that reach the summary judgment stage are dismissed at that point, and those plaintiffs do not have the opportunity to try their cases to a jury.
During pretrial proceedings, a judge is not considered the “fact-finder.” When there are disputes about the facts of a case (that is, when the parties disagree about what actually happened), the judge is required by legal precedent to assume that the facts as stated by the plaintiff are true. In the recent Supreme Court case Tolan v. Cotton, 572 U.S. ___ (May 5, 2014), the Supreme Court reinforced this summary judgment standard and overturned a decision of the Fifth Circuit Court of Appeals, which had mistakenly dismissed the plaintiff’s case.
In Tolan, police sergeant Jeffrey Cotton shot and injured Robert Tolan, whom police mistakenly thought had stolen a car. Tolan was unarmed on his parents’ front porch, and his mother came outside and told the police the car was not stolen. The police ordered Tolan’s mother to stand against the family’s garage door and roughed her up when she expressed incredulity. When Tolan protested this treatment of his mother, Cotton shot him.
The parties disagree about the events surrounding the shooting. According to Tolan, two floodlights illuminated the area; Tolan’s mother protested what the police were doing in a nonthreatening manner; Tolan spoke to Cotton in a normal manner; and Tolan was on his knees when Cotton shot him. The Court of Appeals determined instead that the porch was “fairly dark” at the time of the shooting; that Tolan’s mother was “very agitated” when addressing the police officers; that Tolan was “shouting” and “verbally threatening” Cotton; and that Tolan was on his feet and “moving to intervene” in Cotton’s interaction with Tolan’s mother. Based on these factual conclusions, the Court of Appeals ruled that the police had acted reasonably and did not violate clearly established law in shooting Tolan, thus concluding there was no need for a trial.
The Supreme Court found that the Court of Appeals was wrong to draw factual conclusions. It explained that, in doing so, the lower court was choosing to credit the police officers’ perspective on the facts rather than believing Toland, thus denying Tolan the right to have his claim for injuries decided by a jury.
In overturning the Court of Appeals, the Supreme Court explained that the Court of Appeals had “fail[ed] to credit evidence that contradicted some of its key factual conclusions, … improperly ‘weigh[ed] the evidence’ and resolved disputed issues in favor of” the defendant. Tolan, Slip Op., at 8 (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986)). The court reinforced the principle that a judge’s role, at this stage, is “not ‘to weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for trial.’” Tolan, Slip Op., at 7 (quoting Anderson, 477 U.S., at 249).
This is a very important decision for all plaintiffs in all civil cases. It reminds courts that when a defendant files a summary judgment motion, the court must believe the facts as stated by the plaintiff. This gives the plaintiff the opportunity to present her evidence and allows the jury to determine whose version should be believed.