Flores v. City of South Bend
Court does not insist upon intent-to-harm standard of Co. of Sacramento v. Lewis, applies standard of “criminal recklessness,” which it equates to “deliberate indifference” to high-speed driving by officer that caused accident; holds that this standard is appropriate in non-emergency situation where officer had actual knowledge of unjustifiable risk to human life and consciously disregarded risk; concluding that officer’s reckless conduct, unjustified by emergency, allowed the inference that he subjectively knew of the risk he created and consciously disregarded it.