Course: Introduction / Policing / Procedural Law
Tennessee v. Garner (1985) is a landmark SCOTUS decision where the Court invalidated a Tennessee statute that codified the fleeing felon rule; the use of deadly force to apprehend an unarmed felon is unconstitutional.
See also fleeing felon rule
Tennessee v. Garner is a landmark case that established important limitations on the use of deadly force by law enforcement officers. The case involved a Tennessee statute that authorized police officers to use deadly force to apprehend fleeing suspects, including those who were unarmed. The statute was challenged by the family of Edward Garner, a 15-year-old who was shot and killed by a police officer while attempting to flee from a burglary.
The Supreme Court ultimately held that the Tennessee statute was unconstitutional because it violated the Fourth Amendment’s prohibition on unreasonable seizures. The Court held that the use of deadly force to apprehend an unarmed fleeing suspect is a seizure that must be reasonable under the Fourth Amendment. The Court also held that the reasonableness of the use of deadly force must be determined based on the totality of the circumstances, including the severity of the crime, the danger posed by the suspect, and the threat posed to others.
The decision in Tennessee v. Garner had significant implications for law enforcement practices across the country. Prior to the decision, many states had laws that authorized the use of deadly force to apprehend fleeing suspects, regardless of whether the suspect was armed or posed an immediate threat to others. The decision in Tennessee v. Garner invalidated these laws and established important limitations on the use of deadly force by law enforcement officers.
In the years since the decision, there have been ongoing debates about the appropriate use of deadly force by law enforcement officers. Some critics have argued that the decision in Tennessee v. Garner did not go far enough in limiting the use of deadly force and that more needs to be done to ensure that officers are held accountable when they use excessive force.
In response to these concerns, some states and cities have implemented reforms aimed at reducing the use of deadly force by law enforcement officers. These reforms include increased training for officers, the use of body cameras to document police interactions and changes to police policies and procedures designed to emphasize de-escalation and non-lethal alternatives.
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- Criminal Justice | Section 4.5: The Legal Environment of Policing
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Last Modified: 04/13/2023