County of Sacramento v. Lewis
Is it still good law? What later courts have actually done to this case.
Status
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.
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.
Relying on County of Sacramento v. Lewis?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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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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