On May 15, 2025, the Supreme Court issued a decision in Barnes v. Felix, a case addressing the question of when a police officer’s use of force violates the Fourth Amendment’s prohibition on unreasonable seizures. Lower courts had disagreed about what circumstances surrounding the use of deadly force a court could consider in assessing its reasonableness, with some courts looking “only to the circumstances existing at the precise time an officer perceived the threat inducing him to shoot.” In Barnes, the Supreme Court rejected this narrow rule, indicating instead that courts “must consider all the relevant circumstances, including the facts and events leading up to the climactic moment,” in assessing the reasonableness of an officer’s use of force (including deadly force).
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