The US Supreme Court has delivered a significant ruling in favor of Janice Hughes Barnes, the mother of a Black man shot and killed by police during a routine traffic stop. This unanimous decision, made on Thursday, revives her lawsuit aimed at holding Texas officer Roberto Felix accountable for his use of deadly force, challenging the legal standards previously applied by the US Court of Appeals for the Fifth Circuit.
Justice Elena Kagan, writing for the court, emphasized the necessity of evaluating the totality of circumstances when determining whether an officer's actions were reasonable. “To assess whether an officer acted reasonably in using force, a court must consider all the relevant circumstances, including facts and events leading up to the climactic moment,” Kagan stated. This ruling sets a precedent for how courts should approach cases involving police use of force, particularly in relation to the Fourth Amendment, which protects against unreasonable seizure.
Janice Hughes Barnes alleges that Officer Felix and Harris County violated her son Ashtian Barnes’ Fourth Amendment rights when Felix shot him during a traffic stop in 2016. The officer contended that his use of deadly force was justified as he feared for his safety at that moment. However, the Fifth Circuit had adhered to the "moment-of-threat" rule, which limited the inquiry to whether the officer was in danger at the time of the shooting, disregarding prior events that led to the incident.
Kagan clarified that the correct approach should involve examining the “totality of the circumstances,” without imposing a strict time frame. “Of course, the situation at the precise time of the shooting will often be what matters most; it is, after all, the officer’s choice in that moment that is under review. But earlier facts and circumstances may bear on how a reasonable officer would have understood and responded to later ones,” she noted.
This case was closely monitored by civil rights advocates who expressed concerns that a ruling favoring Felix could hinder efforts to hold police officers accountable for fatal shootings, especially amid ongoing racial justice issues in policing. Fifth Circuit Judge Patrick Higginbotham, in his concurring opinion, criticized the routine nature of the traffic stop that ended in the death of an unarmed Black man, highlighting the issue of qualified immunity that often shields police officers from liability.
While the Supreme Court ruled on the timing of the assessment of reasonableness, it did not address the potential implications of an officer's role in creating a dangerous situation. During the traffic stop, police footage revealed that Ashtian Barnes attempted to drive away while Felix was partially inside the vehicle. Barnes argued that it was unreasonable for an officer to jump onto a moving vehicle and then shoot the driver. However, Kagan indicated that this specific issue was not part of the court’s consideration.
Justice Kagan concluded by stating, “The question presented to us was one of timing alone: whether to look only at the encounter’s final two seconds, or also to consider earlier events serving to put those seconds in context.” She remarked that with this matter resolved, the case would return to lower courts to evaluate the reasonableness of the shooting within the broader timeline established by the Supreme Court.
Justice Brett Kavanaugh, in a concurring opinion joined by Justices Clarence Thomas, Samuel Alito, and Amy Coney Barrett, affirmed that the officer’s actions should be assessed based on the totality of the circumstances. Kavanaugh highlighted the dangers police face during traffic stops, particularly when drivers suddenly pull away, necessitating critical decisions to protect public safety.
The case, known as Barnes v. Felix (U.S., No. 23-1239), marks a pivotal moment in the ongoing discourse surrounding police accountability and the standards governing the use of force, especially in the context of racial justice and civil rights.
