On May 15, 2025, the United States Supreme Court issued the opinion, Barnes v. Felix, a case important to law enforcement.

Case Background:

Officer Roberto Felix stopped Ashtian Barnes for suspected toll violations. When Barnes restarted his car and began to drive off, Felix jumped onto the car’s doorsill and, within two seconds, fired two shots into the vehicle, fatally wounding Barnes. The car stopped shortly after.

Barnes’s mother sued under 42 U.S.C. §1983, claiming excessive force. Lower courts sided with Felix, applying the Fifth Circuit’s “moment-of-threat” rule — which judged reasonableness only based on the officer's perception in the split second he fired, ignoring what led up to that moment. Barnes’s mother appealed to the United States Supreme Court.

Supreme Court Decision:

The Court ruled that use-of-force claims must be evaluated based on the totality of the circumstances, not just the final seconds before the use of force. The Court explained that the totality of the circumstances may include the behavior of the suspect and of the officer in the lead-up to the use of force, such as whether the officer created the need for the use of force.

What This Means for Officers:

An officer’s actions leading up to a use-of-force incident can and will be evaluated in determining the reasonableness of the officer’s actions.
The reasonableness of the use of force depends on the full chain of events, not just whether an officer felt endangered at the last moment.
Training and documentation must emphasize sound decision-making throughout the encounter, not just in moments of crisis.

Officer Safety Note (from concurring opinion):

Justice Kavanaugh highlighted the very real dangers of traffic stops, especially when suspects flee. He emphasized that officers must make split-second decisions under extreme stress — and courts should consider those pressures when assessing conduct.

Bottom Line:

How an officer handles the entire use of force incident, not just the final seconds of it, is central to any review of the use of force.