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The City of Indianapolis and five of its police officers did not violate a deceased man’s constitutional rights when officers initiated a 2020 police chase on a suspect that ultimately resulted in the man’s death, the 7th Circuit Court of Appeals ruled Thursday in upholding a lower court’s decision.
The 7th Circuit found that the officers’ actions in the emergency situation did not support a 14th Amendment claim made by Gayl Flynn, the widow of Edward Flynn.
Edward Flynn died after suspect James Shirley, fleeing from Indianapolis Metropolitan Police Department officers in a high speed pursuit, crashed into Edward’s car and killed him.
According to court documents, in December 2020, officers were dispatched to investigate a potentially stolen vehicle at an auto shop in Indianapolis.
Despite IMPD officers’ attempts to detain the suspect, the suspect backed into one of the officers’ patrol cars, nearly hitting the officer, and left the scene.
Police initiated a high-speed chase that lasted approximately five-and-a-half minutes before the suspect ran a red light and crashed into Edward Flynn as he was driving home from work.
Flynn’s widow, Gayl Flynn, sued the city and five of its officers for violating her husband’s substantive due process rights and for the city failing to train its officers.
The Indiana Southern District Court rejected Flynn’s 14th Amendment claim by applying the intent to harm standard, stating the officers must have had an intent to cause physical harm, and that intent must’ve been “unrelated to the legitimate object of arrest” and “unjustifiable by any government interest.”
Flynn conceded that there was no intent to harm, but argued that the district court should’ve applied the deliberate indifference standard instead, meaning the officer acted recklessly in a non-emergency police pursuit.
The 7th Circuit ruled Flynn’s claim failed due to the police chase being an emergency situation, because before the police chase began, the suspect was in a suspected stolen vehicle, crashed into a patrol car, and nearly hit two police officers.
In such a situation, the court does not assess officers’ 14th Amendment liability for deliberate indifference, the circuit court ruled.
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