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No. 23-1239October Term 2024Decided May 15, 2025

Docket 23-1239October Term 2024 (2024–2025)

Janice Hughes Barnes, Individually and as Representative of the Estate of Ashtian Barnes, Deceased, Petitioner v. Roberto Felix, Jr., et al.

The Supreme Court unanimously struck down the Fifth Circuit's "moment of the threat" doctrine, ruling that Fourth Amendment excessive force claims must be evaluated based on the totality of the circumstances rather than solely the split-second an officer uses force.

Case status

Current stage
Decided
Latest event
Decision released May 15, 2025
Case AcceptedOct 4, 2024
Arguments HeardJan 22, 2025
Decision ReleasedMay 15, 2025
What it's about

The Supreme Court unanimously struck down the Fifth Circuit's "moment of the threat" doctrine, ruling that Fourth Amendment excessive force claims must be evaluated based on the totality of the circumstances rather than solely the split-second an officer uses force. The decision clarifies that courts must consider relevant events leading up to a shooting, not just the immediate instant of the threat.

Question presented

Should courts apply the “moment of the threat” doctrine when evaluating an excessive force claim under the Fourth Amendment?

Case path

United States Court of Appeals for the Fifth Circuit / Decision released May 15, 2025

Area

Criminal Procedure