John Deonarine v. Monica Aguilar, Erroneously Sued as Lopez, et al.
Federal Rule of Civil Procedure 56 prohibits courts from resolving factual disputes or weighing competing evidence at the summary judgment stage. This Court has held that video evidence may override a party's account of events only where the recording blatantly contradicts that account. See Scott v. Harris, 550 U.S. 372 (2007).
Yet as body-camera recordings have become central to civil-rights litigation, courts increasingly treat such recordings as dispositive evidence of probable cause even when the recordings are objectively susceptible to competing reasonable interpretations under Rule 56.
The questions presented are:
1. Whether a court may grant summary judgment in a Fourth Amendment false-arrest action by treating body-camera footage as conclusive evidence of probable cause when the recording is capable of multiple reasonable interpretations, notwithstanding Federal Rule of Civil Procedure 56's requirement that courts view the evidence in the light most favorable to the nonmoving party.
2. Whether the Fourth Amendment permits a court to uphold an arrest at summary judgment based on an officer's interpretation of a criminal statute where the legality of the plaintiff's conduct depends on a detailed statutory licensing framework and the evidence regarding that interpretation (including video evidence and sworn testimony) is disputed.
Whether courts may grant summary judgment in Fourth Amendment false-arrest actions by treating body-camera footage as conclusive evidence of probable cause when the recording is susceptible to multiple reasonable interpretations, contrary to Federal Rule of Civil Procedure 56's requirement to view evidence in the light most favorable to the nonmoving party, and whether the Fourth Amendment permits upholding an arrest at summary judgment based on an officer's interpretation of a criminal statute where the legality of the plaintiff's conduct depends on a detailed statutory licensing framework and the evidence is disputed