Barnes v. Felix
Case Overview
A Texas deputy pulled Ashtian Barnes over for a toll violation, then jumped onto the doorsill of Barnes's moving car and shot him twice, killing him. The Fifth Circuit had a rule that said courts could only evaluate whether the force was reasonable at the precise moment the officer perceived a threat, which cut out everything the officer did to put himself in that position in the first place. The Supreme Court ruled unanimously in May 2025 that the Fourth Amendment requires courts to look at the totality of the circumstances, including what happened before the trigger was pulled, and sent the case back.
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The Conclusion
**The Supreme Court held unanimously that Fourth Amendment excessive force claims require courts to examine the totality of circumstances, not just the moment of perceived threat.** The Court rejected the Fifth Circuit's approach that excluded consideration of the officer's conduct leading up to the use of force.
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