Donald Saucier v. Elliot M. Katz and in Defense of Animals

Summary

The Supreme Court held that the qualified immunity ruling requires analysis not susceptible of fusion with the excessive force claim, reversing the Ninth Circuit's approach of merging these inquiries. The Court ruled the two-step sequential analysis—first determining whether a constitutional right was violated, then whether the right was clearly established—must be followed and reversed the denial of immunity. Justice Ginsburg concurred in the judgment but argued the Graham v. Connor reasonableness test suffices alone, and Justice Souter concurred in parts I and II but would remand for applying the qualified immunity standard.