Jeriel Edwards v. Steven Harmon, et al.

In Scott v. Harris, 550 U.S. 372, 380 (2007), this Court held that when a summary-judgment record includes video evidence, a court should not adopt a nonmovant’s version of facts that is “blatantly contradicted by the record, so that no reasonable jury could believe it.” Petitioner sued police officers who participated in his arrest after he was found in his stationary car, intoxicated. His § 1983 suit alleged officers used excessive force when they forced petitioner to the ground, pressed on his head and back, punched and tased him, struck him with a flashlight, and placed him in a neck restraint designed to interrupt blood flow to his brain. The officers moved for summary judgment, asserting qualified immunity and introducing evidence including one officer’s bodycam video. In opposition, petitioner relied on that video to argue that genuine disputes of material fact required resolution by a jury. See FED. R. CIV. P. 56(c)(1). The Tenth Circuit affirmed the district court’s summary judgment, stating that petitioner’s failure to submit his own evidence influenced its analysis. The question presented is: Does Scott v. Harris alter, or merely implement, traditional summary-judgment requirements—especially when a nonmovant § 1983 plaintiff relies on movants’ video evidence to oppose summary judgment?