In Barnes v. Felix (2025), the U.S. Supreme Court unanimously struck down the 5th Circuit’s “moment-of-threat” rule for evaluating police use of force, reaffirming the broader “totality of the circumstances” standard established in Graham v. Connor. The case involved a fatal police shooting during a traffic stop, where an officer fired as a vehicle began moving with him on the doorsill.

In Estate of Parker v. Mississippi Department of Public Safety (5th Cir. 2025), officers pursuing Eric Smith—a suspect who had murdered two individuals, kidnapped his three‑month‑old son La’Mello Parker, and fired at law enforcement—utilized deadly force when Smith used the infant as a human shield.