Case Citator › County of Sacramento v. Lewis

County of Sacramento v. Lewis

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
523 U.S. 833
Decided
Confirmed treatments
1
Flagged citations read
249 of 249
Citing cases (total)
6,174
Treatment dates
2000

Status

Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Screening is complete: all 249 flagged citations have been read, and the one confirmed adverse treatment is listed below. Hudson v. Hall treated County of Sacramento v. Lewis's suggested sequencing approach as allowing exceptions and did not use it in that qualified-immunity case; the same opinion appeared in three source clusters and is recorded once above.
More on how this was screened

The other reviewed opinions applied Lewis positively, described Lewis's treatment of older authorities, repeated unsupported history parentheticals, or used nearby treatment language about unrelated law.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

6,174 later cases cite County of Sacramento v. Lewis; 249 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Limited

  • The Eleventh Circuit read the qualified-immunity sequencing approach that Lewis suggested as allowing exceptions, and did not use it where deciding the constitutional question first would have required resolving a difficult state-law issue.

    Hudson v. Hall · Eleventh Circuit · filed

    We recognize that the Supreme Court has written that generally we should—when we adjudicate qualified immunity cases—first decide whether the defendant has violated federal law at all before considering whether the law was clearly established. ... But we do not think that the Supreme Court's suggested approach is—without exceptions—required absolutely, and we decline to follow that approach in this instance. In this case, whether probable cause existed—and, whether the Fourth Amendment was violated—turns upon a difficult question of state law. If we followed here the approach set out in Wilson and in Lewis, we would be required to determine whether O.C.G.A. § 40-6-123 applies to turns from private driveways onto public roadways before we reached the clearly-established question.
    Read the full opinion on CourtListener →

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