Barnes v. Felix, Docket No. 23-1239

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Law can turn on a single moment, but the Supreme Court says it’s not enough just to stop the clock at that instant. In Barnes v. Felix, the Court looked at a rule that made judges evaluate police force only by what happened in the split second an officer felt threatened. The Justices all agreed that’s too narrow.

Instead, they said courts must look at the whole story—the moments leading up to the use of force, not just that final flash. In simple terms, it’s like watching the whole game, not just the winning play. By sending the case back to the lower court, the Supreme Court is making sure every part of the encounter gets its fair share of attention.

Summary of the Case

The family of Ashtian Barnes sued Officer Roberto Felix in Barnes v. Felix after he used deadly force during a traffic stop. Barnes was initially pulled over for toll violations. When he began searching through his car and then drove away after being ordered to exit, Officer Felix jumped onto the doorstep of the moving vehicle. Within two seconds, Felix fired two fatal shots. The trial court ruled in favor of the officer, applying a rule that only considered whether danger existed at the exact moment before the shooting. An appeals court agreed, stating that events before the "two-second window" weren't relevant. The Supreme Court then stepped in to decide whether this narrow time focus aligns with the Fourth Amendment's requirement that police actions be "objectively reasonable."

Opinion of the Court

Justice Kagan, writing for a unanimous Court, rejected this "moment-of-threat" approach as improperly limiting Fourth Amendment analysis. The Court reinforced that all excessive force claims must consider the "totality of the circumstances." Because prior events might explain why an officer reasonably perceived danger—or why a suspect's actions were actually harmless—courts cannot wear "chronological blinders" that only focus on the final moment before shots were fired. The Court noted that context, including events leading up to a shooting, can justify an officer's decision to use deadly force. It overturned the lower court's ruling and sent the case back for reconsideration using a complete timeline analysis.

Separate Opinions

Justice Kavanaugh, joined by Justices Thomas, Alito, and Barrett, wrote separately while agreeing with the outcome. He emphasized the dangers officers face during traffic stops and the split-second decisions they must make when drivers flee. While agreeing courts must consider all circumstances, he stressed that judges should recognize the risks to officers and the public, especially when a suspect's "flight could signal a larger danger."

The Timeline Matters in Police Use of Force Cases

The key issue in this case revolves around how much of the timeline courts should examine when judging police use of force. The Fourth Amendment protects people from "unreasonable seizures," including excessive police force. Previous Supreme Court decisions established that reasonableness must be judged from "the perspective of a reasonable officer on the scene," without applying a simplistic test. The Court clarified that while an officer's split-second decision at the moment of firing is crucial, earlier events—such as the suspect's actions, any warnings given, or how the officer approached the situation—are equally important in determining whether force was reasonable. A rule that artificially cuts off consideration of earlier events contradicts the fact-based, context-sensitive approach the law requires. Courts must evaluate the complete picture without arbitrarily limiting their view to just the final moments before force was used.