Tennessee v. Garner

471 U.S. 1, 105 S.Ct. 1694 (1985)

Quick Summary

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Edward Garner’s (plaintiff) father sued after Garner was shot and killed by Officer Hymon (defendant) while fleeing from a suspected burglary. The issue presented to the Supreme Court was whether this use of deadly force was constitutional under the Fourth Amendment.

The Supreme Court held that using deadly force against non-dangerous fleeing suspects violates the Fourth Amendment. The ruling mandated that deadly force can only be used if there is probable cause to believe that the suspect poses a significant threat. The case was remanded for actions consistent with this ruling.

Facts of the Case

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In Memphis, Tennessee, a burglary was reported, and Officers Elton Hymon and Leslie Wright (defendants) responded to the call. Edward Garner (plaintiff), a young unarmed suspect, was seen fleeing the scene by Officer Hymon. When Garner ignored Hymon’s command to halt and began climbing a fence, Hymon, believing Garner was unarmed and posed no immediate threat but would escape if not apprehended, fatally shot him in the back of the head.

Garner’s father sued under 42 U.S.C. § 1983 for violation of his son’s civil rights, arguing that the use of deadly force was unreasonable and thus unconstitutional under the Fourth Amendment.

The case questioned the constitutionality of Tennessee’s statute authorizing deadly force to prevent the escape of an apparently unarmed suspected felon. The lower courts had different views on the matter, leading to an appeal to the United States Supreme Court, which had to consider whether the use of deadly force in such circumstances could be justified.

Procedural Posture and History

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  1. The District Court ruled in favor of the defendants, stating that Officer Hymon’s actions were justified under Tennessee law.
  2. The Court of Appeals reversed the decision, holding that the use of deadly force was not justified as Garner posed no immediate threat.
  3. The State of Tennessee intervened to defend its statute, leading to an appeal to the United States Supreme Court.

I.R.A.C. Format

Issue

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Whether the use of deadly force by police against an unarmed, non-dangerous fleeing suspect is constitutional under the Fourth Amendment.

Rule of Law

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The use of deadly force to prevent the escape of a fleeing suspect is only constitutional if it is necessary to prevent the escape and there is probable cause to believe that the suspect poses a significant threat of death or serious physical injury to others.

Reasoning and Analysis

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The Supreme Court held that while the state’s interest in apprehending criminal suspects is important, it does not justify the use of deadly force against an unarmed and non-dangerous fleeing suspect. The Court emphasized that preserving life is a core value protected by the Fourth Amendment and that law enforcement methods must balance the severity of the crime against the rights of the suspect.

The majority opinion pointed out that modern policing standards and state laws have largely moved away from allowing deadly force in such situations, reflecting a societal consensus that such tactics are excessive when dealing with non-violent suspects.

Moreover, the Court noted that advancements in technology and changes in law have rendered the old common-law rule permitting deadly force against fleeing felons outdated. The decision underscored that an officer’s decision to use deadly force must be based on probable cause that the suspect poses an immediate threat, not merely on the suspect’s flight to avoid arrest for a felony.

Conclusion

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The Supreme Court decided that Tennessee’s statute was unconstitutional to the extent that it authorized deadly force against unarmed, non-dangerous fleeing felons. The case was remanded for further proceedings consistent with this opinion.

Key Takeaways

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  1. The use of deadly force against a fleeing suspect is a seizure under the Fourth Amendment and must be reasonable.
  2. Deadly force cannot be justified solely based on a suspect’s attempt to flee; there must be probable cause to believe they pose a significant threat.
  3. The ruling signifies a shift towards more restrictive use of police force in line with modern standards and societal expectations.

Relevant FAQs of this case

What constitutes 'reasonable' force in the apprehension of a suspect?

The reasonableness of force is determined by balancing the severity of the crime, the immediate threat posed by the suspect to officers or others, and whether the suspect is actively resisting arrest or attempting to evade by flight. Force must be proportionate to the threat encountered.

  • For example: An officer may not use a taser on a suspect passively resisting by going limp, as the force would be disproportionate to the situation.

How does an officer establish probable cause that a suspect poses a significant threat?

Probable cause involves the officer having reasonable grounds to believe based on factual evidence, such as suspect behavior or information received, that the suspect presents an imminent danger of violence or serious harm to others or the officer themselves.

  • For example: If a suspect brandishes a weapon or has made credible threats of violence, an officer may have probable cause to consider them a significant threat.

In what situations might restraint be considered excessive force and thus unconstitutional?

Restraint is considered excessive and unconstitutional when it goes beyond what would be considered proportional and necessary for ensuring safety and compliance. This often involves force being used maliciously or sadistically for the very purpose of causing harm rather than achieving a legitimate law enforcement objective.

  • For example: Shackling a cooperative, non-violent suspect to a fixed object for an extended period could be seen as excessive and punitive rather than precautionary.

References

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