Close
Updated:

Use of deadly force to apprehend a fleeing suspect is generallly unconstitutional. Graham v. Connor, 490 U.S. 386 (1989)

In New York, police misconduct and brutality have been persistent problems for years. Communities, particularly marginalized and minority groups, have raised serious concerns about excessive use of force, racial profiling, harassment, and other forms of misconduct by law enforcement officers. The cases often involve unarmed individuals, and unfortunately, some have resulted in severe injuries or even fatalities.

Tennessee v. Garner, a landmark case decided by the United States Supreme Court in 1985, had a profound impact on law enforcement procedures and civil rights in New York and across the United States. This case redefined the circumstances under which law enforcement officers are allowed to use deadly force, specifically concerning the Fourth Amendment’s protection against unreasonable seizures.

Background
The case revolves around the tragic events that unfolded on the night of October 3, 1974, in Memphis, Tennessee. Officers Leslie Wright and Elton Hymon, responding to a suspected burglary, arrived at a residence and saw a young black male, Edward Garner, fleeing the premises. Believing Garner was the burglar, Officer Hymon fired his service weapon, striking the 15-year-old boy in the back of the head. Tragically, Garner died as a result of this incident.

Following Garner’s death, his father filed a lawsuit against Officer Hymon, alleging that the use of deadly force was unjustified and violated Edward Garner’s Fourth Amendment rights. The trial court had held that the use of deadly force by Officer Hymon in shooting Edward Garner as he was fleeing was reasonable and justified under the circumstances. The case eventually made its way to the United States Supreme Court, seeking clarification on the constitutionality of using deadly force against fleeing suspects.

Holding
On March 27, 1985, the Supreme Court delivered its landmark decision in Tennessee v. Garner. The Court ruled that the use of deadly force to apprehend a fleeing suspect is unconstitutional under the Fourth Amendment unless 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.

This ruling fundamentally altered the legal framework surrounding the use of deadly force by law enforcement officers. Prior to this decision, many states had laws authorizing the use of deadly force against fleeing felons, regardless of the threat they posed. The Court’s decision struck down such laws, emphasizing the need for a careful and reasonable assessment of the circumstances before resorting to lethal force.

Implications and Impact
The implications of the Tennessee v. Garner ruling were profound, as it significantly redefined the rules regarding the use of deadly force by law enforcement officers. The decision acknowledged the importance of safeguarding individual rights while allowing law enforcement to fulfill their duties.

This ruling mandated that law enforcement officers should evaluate the situation and consider whether the suspect poses a genuine threat to themselves or others before using deadly force. It introduced a higher standard of accountability, requiring officers to exercise discretion and judgment, and necessitated a balancing act between public safety and individual rights.

Furthermore, the decision sparked a reevaluation of law enforcement training and practices across the nation. Departments began focusing on de-escalation techniques, crisis intervention training, and emphasizing non-lethal force options to reduce the need for deadly force in encounters with suspects.

Conclusion
Tennessee v. Garner stands as a pivotal case, shaping the landscape of police use of deadly force in New York and across the country.  By highlighting the importance of considering the threat posed by a suspect before resorting to lethal measures, the Supreme Court took a significant step toward protecting citizens’ Fourth Amendment rights.

If you’re a victim of police misconduct in New York, document the incident, gather evidence, file a complaint, and seek medical attention if needed. Contact an experienced New York police brutality lawyer to understand your legal rights and options for seeking justice and compensation. Time is crucial, so act promptly.

Contact Us