Tennessee v. Garner (1985)
Overview
This landmark decision set constitutional limitations on the use of deadly force by law enforcement officers under the Fourth Amendment.
The case arose after a Memphis police officer shot and killed Edward Garner, a 15-year-old burglary suspect, as he attempted to flee over a fence. Garner was unarmed, and the officer later testified that he believed the suspect would escape if not stopped.
Ruling
The Supreme Court held that the use of deadly force to prevent the escape of an unarmed, non-dangerous fleeing suspect is unconstitutional.
Deadly force may only be used if the officer has probable cause to believe that the suspect poses a significant threat of death or serious physical injury to the officer or others.
Legal Principle Established
“A police officer may not seize an unarmed, non-dangerous suspect by shooting him dead.”
Implication
This case established that deadly force must be objectively reasonable under the Fourth Amendment.
A suspect who has previously fired at officers but still retains the weapon may still be considered a continuing threat, even if the weapon is temporarily out of sight.
Quick Guide
- Officers may use deadly force only when a suspect presents an immediate or ongoing threat of serious harm.
- A fleeing suspect who is no longer armed or posing danger cannot be lawfully shot.
- This decision defines the federal standard for use of force, guiding RP policies on proportionality and necessity.
- Violating this standard by shooting a non-threatening, fleeing suspect would constitute excessive force and breach both constitutional and departmental policy.