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Matthew Reid Hinson v. R. A. Bias, et al.

Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 16-14112 · judgment June 14, 2019


Certiorari denied · October 5, 2020
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

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 record—specifically, 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?

Counsel of record

For petitioner
Valentin Leppert
King & Spalding LLP

For respondent
Craig D. Feiser
Office of the General Counsel City of Jacksonville

Case

Conference history
Distributed for 3 conferences

Linked docket
19A472

Proceedings

  1. Nov 20 2020
    Record returned to the U.S.D.C. for the Middle District of Florida (1 envelope).
  2. Oct 05 2020
    Petition DENIED.
  3. Jun 24 2020
    DISTRIBUTED for Conference of 9/29/2020.
  4. Jun 18 2020
    Record received from the U.S.D.C. for the Middle District of Florida (1 envelope). The remainder of the record is available on PACER.
  5. Jun 01 2020
    Record Requested.
  6. Jun 01 2020
    Record received from the U.S.C.A. 11th Circuit. The record is available on PACER.
  7. May 19 2020
    DISTRIBUTED for Conference of 6/4/2020.
  8. May 14 2020
    Reply of petitioner Matthew Reid Hinson filed.
  9. May 04 2020
    Brief of respondents R.A. Bias, et al. in opposition filed.
  10. Apr 01 2020
    Motion to extend the time to file a response is granted and the time is further extended to and including May 4, 2020.
  11. Mar 30 2020
    Motion to extend the time to file a response from April 2, 2020 to May 4, 2020, submitted to The Clerk.
  12. Feb 07 2020
    Motion to extend the time to file a response is granted and the time is extended to and including April 2, 2020.
  13. Feb 05 2020
    Motion to extend the time to file a response from March 2, 2020 to April 2, 2020, submitted to The Clerk.
  14. Jan 31 2020
    Response Requested. (Due March 2, 2020)
  15. Jan 29 2020
    DISTRIBUTED for Conference of 2/21/2020.
  16. Jan 21 2020
    Waiver of right of respondents R.A. Bias, et al. to respond filed.
  17. Jan 10 2020
    Petition for a writ of certiorari filed. (Response due February 13, 2020)
  18. Oct 31 2019
    Application (19A472) granted by Justice Thomas extending the time to file until January 11, 2020.
  19. Oct 29 2019
    Application (19A472) to extend the time to file a petition for a writ of certiorari from November 12, 2019 to January 11, 2020, submitted to Justice Thomas.