More specifically, a state actor who negligently causes an automobile accident cannot be held liable under 42 U.S.C. § 1983 for the injuries suffered by other parties involved in the accident. See, e.g., Cannon v. Taylor, 782 F.2d 947, 950 (11th Cir. 1986) (holding that “a person injured in an automobile accident caused by the negligent, or even grossly negligent, operation of a motor vehicle by a policeman acting in the line of duty has no section 1983 cause of action for violation of a federal right”); Wilcox v. Fenn, 380 Fed.Appx. 837, 839 (11th Cir. 2010) (holding that “Defendants' act in driving over the speed limit when not pursuing a suspect or responding to an emergency may have been negligent-or even grossly negligent-but was not so egregious as to be arbitrary in the constitutional sense.”); Smith v. Sec'y. for Dep't of Corr., 252 Fed.Appx. 301, 302 (11th Cir. 2007) (per curiam) (prisoner failed to state an Eighth Amendment claim when he was “forced, over his complaints, to ride in an allegedly unsafe utility van” in which prison employees failed to fasten prisoner's seatbelt, “so that [the prisoner] was thrown around within the van,” causing injury); Waddell v. Hendry Cty. Sheriff's Off., 329 F.3d 1300, 1305 (11th Cir. 2003) (holding that § 1983 must not be used “as a font of tort law to convert state tort claims into federal causes of action.”).

Nonetheless, even if the deputies did breach a duty of care to the fleeing driver or Kimberly King, a suggestion of negligence alone is not sufficient to state a § 1983 claim for a substantive due process violation. Wilcox v. Fenn, 380 Fed. Appx. 837, 839 (11th Cir. 2010) (officer's negligent behavior "was not so egregious to be arbitrary in the constitutional sense") (citing Lewis, 523 U.S. at 847); Bublitz, 327 F.3d at 491 ("mere negligence is insufficient to give rise to a constitutional violation under the Fourteenth Amendment.").