Case Law Academy

Topic

Use of Force

44 published cases

Use Of Force

Z. J. v. Kansas City Brd of Police Comm

931 F.3d 6722019Court of Appeals for the Eighth Circuit

Z. J. v. Kansas City Brd of Police Comm: for officers executing warrants, this case is a strong warning that a flash-bang grenade is not just a routine entry tool. It is a significant use of force that must be tied to the actual risks known at the time.

Use Of Force

Allen Bloodworth, II v. Kansas City Board of Police Commissioners

89 F.4th 6142023Court of Appeals for the Eighth Circuit

Allen Bloodworth, II v. Kansas City Board of Police Commissioners: the only police-work implication that can be drawn from the supplied material is that this is an Eighth Circuit use-of-force case and may be relevant for officers working in jurisdictions governed by Eighth Circuit precedent. The specific lesson for officers needs source verification from the full opinion.

Use Of Force

N.S. v. Kansas City Board of Police

35 F.4th 11112022Court of Appeals for the Eighth Circuit

N.S. v. Kansas City Board of Police is a reminder that courts separate bad outcomes from constitutional violations. An injury during a police operation is important and may trigger reporting, investigation, supervision review, policy analysis, and possibly state-law claims.

Use Of Force

Charles Byrd v. Phoenix Police Department

885 F.3d 6392018Court of Appeals for the Ninth Circuit

Charles Byrd v. Phoenix Police Department: for officers, the key takeaway is that an arrest-related conviction does not automatically end later civil litigation over force. Even if a subject is convicted of resisting arrest, assaulting an officer, or another offense from the same incident, a court may still allow an excessive-force claim if the alleged force could have occurred separately from the criminal act or after the subject was under control.

Use Of Force

Rudley v. Little Rock Police Dep't

935 F.3d 6512019Court of Appeals for the Eighth Circuit

The main police-work lesson that can be drawn from the limited source material is a cautionary one: use-of-force cases are fact-specific, and officers, supervisors, and trainers should not rely on a case citation without reading the actual facts and holding. Rudley v. Little Rock Police Dep't may be important to Eighth Circuit use-of-force law, but the supplied material is not enough to identify its concrete rule.

Use Of Force

Linda Moser v. Etowah Police Dep't

27 F.4th 11482022Court of Appeals for the Sixth Circuit

For officers, Linda Moser v. Etowah Police Dep't reinforces that constitutional use-of-force analysis starts with identifying who the officer was trying to stop, seize, or restrain. If force is intentionally used to arrest or control a person, the reasonableness of that force will be judged under the Fourth Amendment.

Use Of Force

Frost v. New York City Police Department

980 F.3d 2312020Court of Appeals for the Second Circuit

Frost v. New York City Police Department reinforces a basic Fourth Amendment lesson: the authority to arrest does not automatically justify any amount of force. Officers should be able to explain why the force used was necessary based on the person’s conduct, threat level, resistance, and the operational realities at the scene.

Use Of Force

Snow v. Rochester Police Officer Christopher Schreier

193 A.D.3d 13462021Appellate Division of the Supreme Court of the State of New York

Because the source material does not provide the facts or holding, this case should not be used as a training example for a specific use-of-force rule without checking the actual opinion. For police work, the only grounded takeaway from the supplied material is that Snow v. Rochester Police Officer Christopher Schreier is a New York appellate case involving police use of force.

Use Of Force

Mahdi v. Salt Lake Police Department

54 F.4th 12322022Court of Appeals for the Tenth Circuit

Based only on the provided metadata, Mahdi v. Salt Lake Police Department should be treated as a case requiring further review before it is used in training or policy discussions. Officers should not rely on this summary as authority for a specific tactic because the source material does not identify the force used, the subject’s conduct, the level of threat, or the court’s reasoning.

Use Of Force

Screws v. United States

325 U.S. 911945Supreme Court of the United States

For police officers, Screws v. United States is an early and important reminder that official authority does not shield an officer who uses force as punishment, revenge, intimidation, or any other unlawful purpose. When an officer acts under color of law, the officer is not acting as a private citizen.

Use Of Force

Parratt v. Taylor

68 L. Ed. 2d 4201981Supreme Court of the United States

Parratt v. Taylor is not a use-of-force case. It does not decide when officers may use force, seize a person, or conduct a search.

Use Of Force

Ingraham v. Wright

51 L. Ed. 2d 7111977Supreme Court of the United States

Ingraham v. Wright is not a police arrest or detention force case, and officers should not read it as authority to use force as punishment. The case dealt with school discipline, not law enforcement force.

Use Of Force

Ben Chavez v. Oliverio Martinez

538 U.S. 12003Supreme Court of the United States

Ben Chavez v. Oliverio Martinez is important because it separates two issues that are often blended together in the field: whether a statement can be used in court, and whether the act of questioning creates civil liability. The Court said the Fifth Amendment self-incrimination problem arises when compelled statements are used in a criminal case, not simply because an officer asked questions without Miranda warnings.

Use Of Force

Pembaur v. City of Cincinnati

89 L. Ed. 2d 4521986Supreme Court of the United States

Pembaur v. City of Cincinnati is mainly a municipal-liability case, not a case that rewrites search-warrant or use-of-force rules. Its lesson for officers is that a one-time order from the right official can have major legal consequences for the agency.

Use Of Force

City of Oklahoma v. Tuttle

85 L. Ed. 2d 7911985Supreme Court of the United States

City of Oklahoma v. Tuttle: for patrol officers, City of Oklahoma City v. Tuttle is mainly a municipal-liability case, not a new use-of-force standard. It does not say that an officer’s use of force is lawful just because it happened only once.

Use Of Force

Koon v. United States

135 L. Ed. 2d 3921996Supreme Court of the United States

Koon v. United States should not be read as approval of the force used against Rodney King. The officers’ federal civil-rights convictions were not erased by this decision.

Use Of Force

County of Sacramento v. Lewis

140 L. Ed. 2d 10431998Supreme Court of the United States

County of Sacramento v. Lewis is an important use-of-force and pursuit case because it recognizes the realities of fast-moving police decisions. The Supreme Court did not say that pursuits are risk-free or that officers have unlimited authority to chase.

Use Of Force

Chavez v. Martinez

155 L. Ed. 2d 9842003Supreme Court of the United States

Chavez v. Martinez is important for officers because it separates two related but different concepts: questioning someone without Miranda warnings and violating the Fifth Amendment Self-Incrimination Clause. If officers question a suspect without Miranda warnings, the likely consequence in a criminal case is that the statement may be excluded from evidence.

Use Of Force

Atwater v. City of Lago Vista

149 L. Ed. 2d 5492001Supreme Court of the United States

Atwater v. City of Lago Vista gives officers a constitutional baseline: if you have probable cause that a person committed a criminal offense in your presence, the Fourth Amendment generally allows a custodial arrest, even for a very minor misdemeanor. The case is especially important in traffic and low-level offense settings, where officers often must decide between a citation, warning, summons, or arrest.

Use Of Force

United States v. James Daniel Good Real Property

126 L. Ed. 2d 4901993Supreme Court of the United States

For police officers, detectives, and supervisors, United States v. James Daniel Good Real Property is a reminder that civil forfeiture involving houses, land, or other real property has constitutional limits. Even when officers have strong evidence that a property was used in drug activity, the government normally cannot simply take control of that real property without giving the owner notice and a chance to be heard.

Use Of Force

Ziglar v. Abbasi

582 U.S. 1202017Supreme Court of the United States

For federal officers, Ziglar v. Abbasi is important because it limits when a person can sue individual federal officials for money damages directly under the Constitution. If a claim arises in a new context, especially one involving national security, immigration, detention policy, or high-level operational decisions, courts will be reluctant to create a new Bivens remedy unless Congress has clearly provided for it.

Use Of Force

Albright v. Oliver

127 L. Ed. 2d 1141994Supreme Court of the United States

Albright v. Oliver is not a use-of-force case, and it does not set rules for how much physical force officers may use. Its value for officers is in understanding how courts classify constitutional claims arising from arrests and criminal charges.

Use Of Force

Wood v. Moss

188 L. Ed. 2d 10392014Supreme Court of the United States

For police officers, Wood v. Moss is a reminder that crowd-control decisions near protected persons, public officials, or sensitive locations should be grounded in real security considerations. If one group is closer to a threat area, has better access to a protected person, or presents a different line-of-sight issue, officers may have a lawful basis to move that group even if the group is engaged in political speech.

Use Of Force

City and County of San Francisco v. Sheehan

575 U.S. 6002015Supreme Court of the United States

City and County of San Francisco v. Sheehan is important for officers responding to mental health crisis calls involving weapons. The case recognizes that mental illness is part of the total situation, but it does not eliminate the officer’s right to protect life when a person presents an immediate threat with a deadly weapon.

Use Of Force

Brosseau v. Haugen

160 L. Ed. 2d 5832004Supreme Court of the United States

For officers, Brosseau v. Haugen is mainly a qualified-immunity case, not a broad use-of-force permission slip. The Supreme Court protected the officer from personal civil liability because the law at the time did not clearly establish that her specific action was unconstitutional.

Use Of Force

Hernandez v. Mesa

582 U.S. 5482017Supreme Court of the United States

Hernandez v. Mesa: for officers, the most important operational lesson is that use-of-force decisions are judged based on the facts reasonably known to the officer at the moment force is used. Later-discovered information may matter for investigation or context, but it cannot normally be used to prove that an officer made a reasonable decision if the officer did not know it at the time.

Use Of Force

Thompson v. Clark

596 U.S. 362022Supreme Court of the United States

Thompson v. Clark is not mainly a use-of-force case, even though it arose from a police response at a home and an arrest. Its main importance for police work is in the area of arrests, criminal complaints, and later civil litigation.

Use Of Force

Torres v. Madrid

592 U.S. 3062021Supreme Court of the United States

For police officers, Torres v. Madrid means that an unsuccessful attempt to stop a person with intentional physical force can still count as a seizure. If an officer fires at a person to stop that person and the person is hit, the Fourth Amendment is implicated even if the person drives away, runs away, or is not immediately handcuffed.

Use Of Force

White v. Pauly

580 U.S. 732017Supreme Court of the United States

White v. Pauly is important for officers because it shows how courts analyze split-second force decisions and qualified immunity. The Supreme Court recognized that Officer White entered an already dangerous situation and had very little time to react.

Use Of Force

Tolan v. Cotton

188 L. Ed. 2d 8952014Supreme Court of the United States

Tolan v. Cotton is a reminder that use-of-force cases often turn on small factual details. In a deadly force case, courts will look closely at what the officer saw, what the person did, the person’s position and movement, the distance involved, whether commands were given, whether the person appeared armed, and whether witnesses support or contradict the officer’s account.

Use Of Force

Kingsley v. Hendrickson

576 U.S. 3892015Supreme Court of the United States

Kingsley v. Hendrickson matters most in custodial settings involving pretrial detainees, such as jails, holding facilities, and similar detention environments. The case does not say that officers cannot use force in jail.

Use Of Force

Mullenix v. Luna

577 U.S. 72015Supreme Court of the United States

Mullenix v. Luna is important for officers because it shows how qualified immunity works in use-of-force cases, especially vehicle pursuit cases. The decision does not say that officers may freely shoot at fleeing vehicles.

Use Of Force

Kisela v. Hughes

584 U.S. 1002018Supreme Court of the United States

For officers, Kisela v. Hughes reinforces that courts evaluate use-of-force decisions from the perspective of what officers reasonably knew at the time, not with the benefit of hindsight. Facts discovered later, such as whether the potential victim actually felt afraid, may matter in the broader case, but they do not control what the officer reasonably perceived in the moment if the officer did not know them.

Use Of Force

Egbert v. Boule

596 U.S. 4822022Supreme Court of the United States

For federal officers, especially those working in border, immigration, or national-security-related assignments, Egbert v. Boule makes it much harder for plaintiffs to bring new Bivens damages claims. The decision signals that courts will usually defer to Congress rather than create new personal-capacity damages remedies against federal officers.

Use Of Force

Rivas-Villegas v. Cortesluna

595 U.S. 12021Supreme Court of the United States

For officers, Rivas-Villegas v. Cortesluna is primarily a qualified-immunity case, not a broad approval of any particular control technique. The decision recognizes that officers may need to use brief physical control while securing a suspect, especially after a serious domestic-violence call involving a reported threat and a visible weapon.

Use Of Force

City of Tahlequah v. Bond

595 U.S. 92021Supreme Court of the United States

For officers, City of Tahlequah v. Bond is mainly a qualified immunity case, not a use-of-force training manual. The Supreme Court did not say that every similar shooting is automatically lawful.

Use Of Force

City of Escondido v. Emmons

586 U.S. 382019Supreme Court of the United States

City of Escondido v. Emmons does not give officers a blanket rule allowing takedowns whenever they respond to a domestic violence call. It also does not say the force used was necessarily constitutional on the merits.

Use Of Force

Barnes v. Felix

605 U.S. 732025Supreme Court of the United States

Barnes v. Felix is important because it reinforces that use-of-force decisions will be judged in context. Officers should expect that courts, agencies, and attorneys will examine not only the instant when force was used, but also the lead-up to that moment.

Police Pursuits

Scott v. Harris

550 U.S. 3722007Supreme Court of the United States

Scott v. Harris is the Supreme Court's major police-pursuit force case. It explains when force used to end a dangerous high-speed chase can be reasonable under the Fourth Amendment.

Use of Force

Plumhoff v. Rickard

572 U.S. 7652014Supreme Court of the United States

Plumhoff v. Rickard held that officers did not violate the Fourth Amendment when they used deadly force to stop a person fleeing police in a high-speed chase that endangered the public. The Court also held the officers were protected by qualified immunity in any event.

Use of Force

Graham v. Connor

490 U.S. 3861989Supreme Court of the United States

Graham v. Connor established that police excessive-force claims during arrests, stops, or seizures are governed by Fourth Amendment objective reasonableness. The rule focuses on the facts confronting officers at the scene, including severity of the suspected offense, immediate safety threats, and resistance or flight, while avoiding hindsight and subjective-intent tests.

Use of Force

County of Los Angeles v. Mendez

581 U.S. 4202017Supreme Court of the United States

In County of Los Angeles v. Mendez, the Supreme Court rejected the Ninth Circuit's provocation rule. The Court held that a prior Fourth Amendment violation does not automatically convert a later reasonable use of force into unconstitutional excessive force, though the prior violation may still support damages under proximate-cause principles.