Police use of force
Tolan v. Jeffrey Wayne Cotton
In brief
The Supreme Court sent Tolan’s case back to the Fifth Circuit and left Cotton’s entitlement to qualified immunity unresolved.
- Where it stands
- Decided
Decided · May 5, 2014 · Per curiam
- What it’s about
- Robert Tolan sued police officer Jeffrey Cotton after Cotton shot him outside Tolan’s parents’ home; the dispute concerned whether Cotton had qualified immunity, a legal protection that can shield government officials from certain lawsuits.
- Who it affects
- The Fifth Circuit must continue Tolan’s case; the Supreme Court did not decide whether Cotton was entitled to qualified immunity, a legal protection that can shield officials from some lawsuits.
Summary: written with AI from the case record.
What it's about
The Supreme Court wiped out the Fifth Circuit’s judgment (vacated it) and sent the case back to that court (remanded it), without deciding whether Cotton was entitled to that protection.
The case asked whether judges should consider what happened during a police encounter when deciding if the legal rule was clear enough to deny an officer qualified immunity.
Question presented
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?
What the Court decided
Holding
The judgment of the United States Court of Appeals for the Fifth Circuit is vacated, and the case is remanded for further proceedings consistent with this opinion.
- Result
- Vacated
The vote
- Majority author
- Per Curiam
What's next
The Fifth Circuit will continue the case in line with the Supreme Court’s opinion.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: Tolan
More questions
- What did Justice Alito say about Supreme Court review in Tolan’s case?
- He warned that granting review here could substantially change the Court’s usual practice if followed in other cases.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.