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Supreme Court has consistently ruled that deadly force cannot be used solely to prevent a suspect from fleeing, even if they are driving a vehicle.

In Tennessee v. Garner (1985), the Supreme Court established that an officer may not use deadly force against an unarmed, non-dangerous fleeing suspect. The Court held that „an officer may not seize an unarmed, nondangerous suspect by shooting him dead,“ setting a foundational Fourth Amendment standard.
The Court reaffirmed this principle in Plumhoff v. Rickard (2014), where it ruled that deadly force was lawful only because the suspect was engaged in a dangerous, high-speed chase exceeding 100 mph, posing a severe threat to public safety. The Court emphasized that mere flight is not enough—there must be an imminent threat of death or serious injury.
In Barnes v. Felix (2025), the Court unanimously rejected the „moment of threat“ doctrine, which limited review to a narrow window of time. Instead, courts must evaluate the totality of the circumstances, including the reason for the stop (e.g., a minor unpaid toll), to determine if deadly force was objectively reasonable. This reinforces that a trivial offense does not justify lethal force.
The Court has also stressed that officers cannot create their own danger—for example, by stepping into a vehicle’s path—then claim self-defense. As stated in Baynes v. Cleland, „an officer should not create a danger by jumping in front of a car, then claim self-defense.“

Bottom line: The Supreme Court has made clear that deadly force is unlawful when used solely to prevent escape, unless the suspect’s actions present an immediate threat to life.

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