Effective Date: 2023-10-14
This case helps clarify when it's lawful for law enforcement officers to use lethal force to apprehend a fleeing suspect.
In 1974, Memphis police officer Elton Hymon responded to a call about a suspected burglary. While investigating, he saw Edward Garner, a 15-year-old, running from the scene. Hymon believed Garner was unarmed, and as Garner was climbing a fence to escape, the officer shot him, causing his death. It was later determined that Garner was not armed and was trying to flee.
The central issue in this case was whether the use of deadly force to prevent the escape of an unarmed, non-dangerous suspect was a violation of the suspect's Fourth Amendment rights against unreasonable seizures.
The U.S. Supreme Court ruled in favor of Edward Garner's family, establishing a significant legal principle. The Court held that it is unconstitutional for a police officer to use deadly force to apprehend a fleeing suspect unless the officer has probable cause to believe that the suspect poses a significant threat of death or serious physical harm to the officer or others.
In simpler terms, the decision in Tennessee v. Garner means that police can only use deadly force when they have a reasonable belief that the suspect is armed, dangerous, and likely to harm someone. They can't use lethal force to stop a suspect who is running away and doesn't present an immediate threat. This ruling helps protect the rights and safety of individuals who might be fleeing from the police but do not pose a clear danger. It sets boundaries on when deadly force can be used in such situations.
Scenario 1 - The Suspected Shoplifter: Officer Davis responds to a call about a suspected shoplifter fleeing from a store. He arrives at the scene and sees a person, Chris, running away from the store. Chris does not appear to be carrying a weapon and is not behaving aggressively. Officer Davis, without hesitation, draws his firearm and shoots at Chris as he attempts to escape.
Question: Was Officer Davis's use of deadly force in compliance with the principles of Tennessee v. Garner? Why or why not?
Answer: No, Officer Davis's use of deadly force was not in compliance with the principles of Tennessee v. Garner. In this scenario, Chris did not appear to be armed or dangerous, and he was fleeing from a non-violent property crime. The principles from Tennessee v. Garner require that deadly force can only be used when the suspect poses a significant threat of death or serious physical harm to the officer or others.
Scenario 2 - The Park Altercation: Officer Rodriguez is patrolling a park when he encounters an altercation between two individuals, Mike and Alex. Mike is seen attacking Alex with a baseball bat. Alex manages to escape and starts running away. Officer Rodriguez, fearing for Alex's safety, fires his weapon at Mike as he runs.
Question: Did Officer Rodriguez's use of deadly force comply with the principles of Tennessee v. Garner? Why or why not?
Answer: Officer Rodriguez's use of deadly force is more likely to comply with the principles of Tennessee v. Garner in this scenario. The use of deadly force may be justified when there is a reasonable belief that a suspect poses a significant threat of death or serious physical harm to others. However, the specific circumstances of the altercation and the threat level must be evaluated to determine compliance with the law.
Scenario 3 - The Unarmed Suspect: Officer Martinez is pursuing a suspect, Lisa, who is fleeing on foot after being identified as a suspect in a non-violent property crime. Lisa is not armed and does not display any aggressive behavior. Officer Martinez decides to use a taser to apprehend her.
Question: Did Officer Martinez's use of a taser to apprehend Lisa comply with the principles of Tennessee v. Garner? Why or why not?
Answer: Officer Martinez's use of a taser to apprehend Lisa is more likely to comply with the principles of Tennessee v. Garner. The use of non-lethal force, such as a taser, may be appropriate to stop a fleeing suspect who does not pose a significant threat of death or serious physical harm. However, the appropriateness of force should still be assessed based on the specific circumstances of the situation and the threat level presented by the suspect.
Question: In what situations can the police use deadly force, according to the Tennessee v. Garner decision?
Answer: Police can use deadly force when they have a reasonable belief that the suspect poses a significant threat of death or serious physical harm to the officer or others.
Question: What was the key issue in the Tennessee v. Garner case?
Answer: The main issue was whether using deadly force to apprehend an unarmed, non-dangerous suspect fleeing the scene violated the suspect's Fourth Amendment rights against unreasonable seizures.
Question: How does Tennessee v. Garner impact law enforcement practices?
Answer: The decision restricts the circumstances under which police can use lethal force during the apprehension of fleeing suspects, emphasizing the protection of both individual rights and the safety of law enforcement officers.