In a unanimous ruling on Thursday, the U.S. Supreme Court rejected a controversial legal standard that had allowed courts to judge police shootings solely by the officer’s perspective in the instant deadly force was used. The decision sets a new precedent, requiring courts to evaluate the totality of the circumstances in excessive force cases under the Fourth Amendment.
The ruling came in the case of Barnes v. Felix, involving the 2016 shooting death of Ashtian Barnes during a traffic stop in Texas. Officer Roberto Felix had ordered Barnes to exit his vehicle. When Barnes turned on the ignition and began to drive away, Felix jumped onto the doorsill of the moving car and fired two shots inside, fatally wounding Barnes. The encounter lasted approximately five seconds.
Lower courts relied on narrow “moment-of-threat” rule
The Fifth Circuit Court of Appeals had upheld summary judgment in favor of Officer Felix, applying its “moment-of-threat” rule. Under that standard, the courts only considered whether Felix reasonably feared for his life during the two seconds he was clinging to the car. Events leading up to that moment—including the nature of the stop and Felix’s own actions—were deemed irrelevant.
But the Supreme Court overturned that approach. Writing for the Court, Justice Elena Kagan emphasized that use-of-force cases must consider “the totality of the circumstances” and not place “chronological blinders” on earlier interactions or decisions.
Court: Context matters in determining reasonableness
“The moment-of-threat rule… prevents that sort of attention to context, and thus conflicts with this Court’s instruction,” Justice Kagan wrote. She pointed to prior rulings, including Plumhoff v. Rickard, which held that deadly force could be justified partly based on a suspect’s earlier dangerous conduct.
The Court did not rule on whether Felix’s actions were constitutional, instead sending the case back to the lower courts for reconsideration under the broader standard.
Concurring opinion stresses officer danger during traffic stops
In a concurring opinion, Justice Brett Kavanaugh—joined by Justices Thomas, Alito, and Barrett—highlighted the inherent risks of traffic stops for law enforcement. He cited multiple real-world examples where officers were killed during stops and noted that drivers who flee can pose significant threats to public safety.
While the concurrence acknowledged the need to hold officers accountable for excessive force, it warned against judging their actions “with the 20/20 vision of hindsight” in high-pressure, split-second situations.
What this means for future police use-of-force cases
The decision in Barnes v. Felix has far-reaching implications. By requiring courts to consider the broader context of police-civilian interactions, it could lead to more scrutiny of officer conduct in deadly force cases—especially where officers contribute to the danger or escalate routine encounters.
The ruling reinforces that constitutional analysis under the Fourth Amendment demands nuance, not a narrow snapshot.
The case now returns to the Fifth Circuit for further proceedings.
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