This case involves a tragic high-speed police chase in Oakland, California, that resulted in the death of a suspect and severe injuries to innocent bystanders. On June 25, 2022, Oakland Police Officers Walid Abdelaziz and Jimmy Marin-Corcel pursued a suspect they believed was involved in an illegal car rally. Despite departmental policy restricting high-speed chases to violent crimes, the officers pursued the suspect through busy city streets at speeds exceeding 60 miles per hour without activating lights or sirens. The chase ended when the suspect lost control of his vehicle and crashed into a group of people waiting near a taco truck. The suspect died, and several bystanders, including the estate of Lolomania Soakai and his family members, suffered severe injuries. The officers witnessed the crash but allegedly drove away without rendering aid or summoning emergency services, later returning to the scene only after hearing other officers approach. The plaintiffs sued the officers under 42 U.S.C. § 1983, alleging violations of their Fourteenth Amendment substantive due process rights. The district court denied the officers' motion for judgment on the pleadings based on qualified immunity, and the officers appealed.
The panel, writing for the majority, addressed two distinct theories of liability under the Fourteenth Amendment's substantive due process clause. First, regarding the 'purpose-to-harm' claim, the court applied the stringent standard required for high-speed chases, which demands proof that the officer acted with the specific intent to harm for reasons unrelated to legitimate law enforcement objectives. The court rejected the officers' argument that a bystander must prove the officer specifically intended to harm that bystander. Instead, the court held that under Supreme Court precedent in County of Sacramento v. Lewis and Ninth Circuit cases like Onossian and Moreland, an officer owes a duty to all those in the vicinity, including bystanders, to limit their intent to harm to legitimate law enforcement purposes. The court reasoned that because the risks of a high-speed chase are foreseeable to all nearby, it would be illogical to distinguish between the intended target and bystanders when determining if the conduct 'shocks the conscience.' The court found that the plaintiffs plausibly alleged the officers chased with the purpose of making the suspect crash and die, which satisfies the purpose-to-harm test. Second, regarding the 'state-created danger' claim, the court held that while the Due Process Clause generally does not confer an affirmative right to government aid, an exception exists when the state affirmatively places an individual in danger and then acts with deliberate indifference to that danger. The court found that the officers' initiation of the chase created a foreseeable danger, and their subsequent failure to summon aid or render help, despite witnessing the carnage, constituted deliberate indifference. The court emphasized that this theory applies to the additional harm caused by the delay in medical treatment, not the crash itself. The court concluded that existing precedent from cases like Wood v. Ostrander and Bracken v. Okura provided fair warning that such conduct was unconstitutional, making the right clearly established.
This decision allows plaintiffs injured by high-speed police chases to proceed with substantive due process claims against officers who acted with an improper purpose to harm the suspect, even if the officers did not specifically target the bystanders. It clarifies that the 'purpose-to-harm' test applies to bystanders and that the law was clearly established to this effect prior to the incident. Additionally, the ruling establishes that officers who create a danger through a chase and then fail to summon aid with deliberate indifference may face liability for the resulting worsening of injuries. The case is remanded to the district court for further proceedings, as the court affirmed the denial of qualified immunity at the motion-to-dismiss stage but expressed no opinion on the ultimate merits of the claims at summary judgment or trial.
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