Supreme Court's 6-3 Garner Ruling Redefined Police Deadly Force Standards in 1985

Washington D.C. – In a landmark 6-3 decision on March 27, 1985, the U.S. Supreme Court fundamentally altered the legal framework governing the use of deadly force by law enforcement officers against fleeing suspects. The ruling in Tennessee v. Garner declared that using deadly force to prevent the escape of an unarmed, non-dangerous fleeing felony suspect constitutes an "unreasonable seizure" under the Fourth Amendment of the U.S. Constitution. This decision mandated that deadly force is only permissible when an officer has probable cause to believe the suspect poses a significant threat of death or serious physical injury to the officer or others.

The case originated from an incident on October 3, 1974, in Memphis, Tennessee. Police Officer Elton Hymon fatally shot 15-year-old Edward Garner, an unarmed suspect, as Garner attempted to flee over a fence after a nighttime burglary. Officer Hymon acted under a Tennessee statute that permitted officers to use "all necessary means to effect the arrest" of a fleeing felon. Garner's father subsequently filed a lawsuit, arguing that the use of deadly force violated his son's constitutional rights.

Prior to Garner, many jurisdictions adhered to the English common law "fleeing felon" rule, which allowed officers to use lethal force to apprehend any fleeing felony suspect. However, the Supreme Court rejected this historical precedent, noting that it arose in an era when most felonies were punishable by death and before the widespread use of firearms. The Court emphasized that modern legal and technological contexts rendered the old rule outdated and disproportionate.

The Garner decision significantly influenced law enforcement practices across the United States. Police departments were required to revise their use-of-force policies to align with the new constitutional standard. Studies, such as one by Abraham N. Tennenbaum, later indicated a significant reduction in police homicides nationwide, with approximately a 16% decrease observed after the ruling. This reduction was particularly pronounced in states that had previously maintained the broader common law rule.

Despite its broad impact, the ruling was not without dissent. Justice Sandra Day O'Connor, in her dissenting opinion, highlighted the challenging, split-second decisions officers face and argued that the ruling could create a "constitutional right to flight" for burglary suspects. The legal standard for police use of force was further refined by the 1989 Supreme Court case Graham v. Connor, which established the "objective reasonableness" standard, judging an officer's actions from the perspective of a reasonable officer on the scene, accounting for the dynamic nature of such encounters.

The Tennessee v. Garner ruling remains a cornerstone of Fourth Amendment jurisprudence, balancing effective law enforcement with the protection of individual rights against excessive force.