Case Citation: Tennessee v. Garner, 471 U.S. 1 (1985)
Decision Date: March 27, 1985
Legal Focus: Fourth Amendment of the U.S. Constitution
Key Holding: Law enforcement officers may use deadly force against a fleeing suspect only if they have probable cause to believe the suspect poses a significant threat of death or serious physical injury to the officer or others.
Case Background
Incident Date: October 3, 1974
Location: Memphis, Tennessee
Involved Parties: Memphis police officers (Leslie Wright and Elton Hymon) and fleeing suspect Edward Garner (15 years old).
Event: Officer Hymon shot Garner, believing he was unarmed but would escape over a fence. Garner was killed by the shot.
Legal Basis: Hymon acted under a Tennessee statute and Memphis Police Department policy allowing deadly force against fleeing suspects.
Legal Proceedings
Initial Court Decision: The District Court found the actions constitutional.
Appeal Outcome: The Sixth Circuit Court of Appeals reversed the decision, ruling the use of deadly force in this instance was unreasonable under the Fourth Amendment.
Supreme Court Decision: Upheld the Appeals Court decision that the Tennessee statute did not appropriately limit the use of deadly force.
Key Legal Issues
Seizure Definition: The court determined that using deadly force against a fleeing suspect constitutes a seizure under the Fourth Amendment.
Reasonableness: The decision emphasized the need to assess the reasonableness of the force used based on the totality of the circumstances.
Court Opinions
Majority Opinion
Justice White emphasized the balance between the suspect's Fourth Amendment rights and government interests.
Historical Context: Criticized the outdated common law rule justifying deadly force against fleeing felons.
Current Impact: Highlighted that the use of deadly force deters little in terms of crime prevention or public protection.
Dissenting Opinion
Justice O'Connor, joining Burger and Rehnquist, argued the necessity for officers to make swift decisions and the validity of the Tennessee statute in protecting public safety.
Impact and Legacy
Civil Rights Context: Brought under 42 U.S.C. 1983, impacting state police practices.
Practical Impact: Less change than anticipated at state-level police practices due to the deferential standard established by subsequent rulings like Graham v. Connor.
Empirical Evidence: Documented reduction in police homicides after the decision, particularly in states that adjusted their laws.
Related Cases: Graham v. Connor (1989), White v. Pauly (2017).
Conclusion
Tennessee v. Garner has a profound legacy in shaping the legal standards surrounding police use of deadly force, emphasizing the necessity for probable cause and the unconstitutionality of unreasonable seizures. Despite challenges in altering state-level practices, it has influenced discussions and policies on police discretion and civil rights.