IRAC Summary of Tennessee v. Garner (1985)
Issue: Whether the use of deadly force against an unarmed fleeing suspect who poses no immediate threat to the officer or others is a violation of the Fourth Amendment’s prohibition against unreasonable seizures.
Rule: The Fourth Amendment to the United States Constitution prohibits “unreasonable searches and seizures” by the government. Court precedents determine reasonableness based on a balancing test of the nature of the intrusion against the government’s interests.
Application: In this case, the application of deadly force was found to be an unreasonable seizure. Garner, a suspect in a burglary, was shot and killed by a police officer while he was fleeing the scene. He was unarmed and posed no immediate threat to the officer or others. The use of deadly force in such a situation, without probable cause to believe that the suspect poses a threat of serious physical harm, is an excessive intrusion upon the individual’s rights.
Conclusion: The Supreme Court held that the use of deadly force to prevent the escape of an apparently unarmed suspect is an unreasonable seizure under the Fourth Amendment.
Detailed IRAC Outline
Issue: The detailed issue in Tennessee v. Garner is the constitutionality of using deadly force to apprehend a fleeing suspect who is not an immediate threat.
Rule: The Court established a more specific rule for the use of deadly force by law enforcement. Deadly force may not be used unless it is necessary to prevent the escape and the officer has probable cause to believe that the suspect poses a significant threat of death or serious physical injury to the officer or others.
Application:
– Relevant Facts: Edward Garner, a 15-year-old suspected of burglary, was shot and killed by a Memphis police officer when he attempted to flee the scene of the crime. Garner was unarmed and was shot as he attempted to climb over a fence. The officer was acting under a Tennessee statute that allowed the use of deadly force against a fleeing suspect.
– Lower Court Holdings: The District Court found for the police officer, but the Court of Appeals reversed, leading to the Supreme Court’s review.
– Supreme Court’s Analysis: The Court noted that the use of deadly force against a fleeing suspect must be balanced against the Fourth Amendment’s protection from unreasonable seizures. The Court analyzed common law and the evolving standards of decency and determined that the use of deadly force in these circumstances was not justifiable. The government’s interest in apprehending criminal suspects does not outweigh an individual’s right to life and the Fourth Amendment’s guarantee against the use of excessive force in a seizure.
– Dissenting Opinion: The dissent in the case argued that the ruling would put law enforcement officers and the public at greater risk by limiting the officers’ authority to act decisively in potentially dangerous situations.
Conclusion: The Supreme Court concluded that the Tennessee statute was unconstitutional insofar as it authorized the use of deadly force against unarmed, non-dangerous fleeing suspects. The Court struck down the use of deadly force in this context, requiring a threat of serious physical harm as a condition for such force to be considered reasonable, and thus constitutional, under the Fourth Amendment.