In Barnes v. Felix, 605 U.S. 73 (2025), the United States Supreme Court unanimously held that courts evaluating Fourth Amendment excessive-force claims must consider the totality of the circumstances, rejecting the Fifth Circuit’s “moment-of-threat” doctrine, which limited the analysis to the seconds immediately preceding an officer’s use of force. The decision reinforces that courts must assess the full context of an encounter rather than focusing solely on an officer’s perception of danger at the precise moment force was used.
Background
The case arose from a traffic stop in which Officer Roberto Felix stopped Ashtian Barnes for suspected toll violations. When Felix ordered Barnes out of the vehicle, Barnes restarted the car and began to drive away. Felix stepped onto the vehicle’s doorsill and, approximately two seconds later, fired two shots into the vehicle, killing Barnes.
Barnes’ mother brought a claim under 42 U.S.C. § 1983, alleging that Felix used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to the officer, finding that the use of force was reasonable because in the two seconds prior to using deadly force, he was standing on a moving vehicle and therefore reasonably feared serious harm. The Fifth Circuit affirmed the granting of summary judgment for the same reasons and emphasized that in the two seconds immediately preceding the use of force, Felix had reason to fear serious harm.
Supreme Court’s Holding
The Supreme Court found this moment-of-threat inquiry to be far too limited and in direct conflict with the Court’s precedent requiring an inquiry into the totality of the circumstances. Writing for the Court, Justice Kagan explained that the Fourth Amendment’s objective-reasonableness inquiry requires courts to examine the totality of the circumstances, including facts and events leading up to the use of force. A court cannot meaningfully evaluate reasonableness if it limits its review to a narrow slice of time immediately preceding the shooting.
A significant aspect of the Court’s analysis was its discussion of Plumhoff v. Rickard, a prior police-chase case involving a driver who led officers on a dangerous, high-speed pursuit before officers used deadly force. The Court explained that Plumhoff itself demonstrated why context matters: the shooting was deemed reasonable not simply because of what occurred at the instant force was used, but because of the driver’s reckless conduct throughout the preceding five-minute chase. A reasonable officer’s assessment of the threat depended on the entire course of events. The Court used Plumhoff to illustrate that its excessive-force jurisprudence has long required consideration of the broader factual context, rather than a snippet from the final moments.
The Supreme Court also rejected Felix’s argument that lower courts were considering the totality of the circumstances; the “moment-of-threat” doctrine just prevented them from second-guessing whether an officer’s mistake “created the need” for deadly force. The Court noted that was perhaps a mischaracterization of Fifth Circuit law and certainly not an accurate reflection of what the lower courts did in this case because both the district court and the Fifth Circuit discussed only the two seconds prior to the use of deadly force where Felix was standing on the moving vehicle. Because the decisions below imposed a temporal limitation on the Fourth Amendment inquiry, the Court held that they could not be reconciled with the required totality-of-the-circumstances analysis.
Importantly, however, the Court did not decide whether an officer’s own conduct in creating or escalating a dangerous situation should factor into the constitutional analysis. The Court repeatedly stressed that the only question before it was whether courts may disregard earlier events when assessing reasonableness. The separate issue of “officer-created danger” remains unresolved and was left for the lower courts to address on remand.
Concurrence
Justice Kavanaugh emphasized the dangers officers face during traffic stops and noted that a driver’s decision to flee substantially increases risks to officers, bystanders, and the public. He further observed that officers confronting a fleeing vehicle often have no risk-free options and that courts must avoid judging split-second decisions with the benefit of hindsight.
Takeaway for Municipalities and Law Enforcement
Barnes reaffirms that excessive-force claims remain governed by the familiar objective-reasonableness standard. However, the decision makes clear that courts may not artificially limit their analysis to the final moments before force is used. Instead, courts must evaluate all relevant facts and circumstances that bear on the reasonableness of the officer’s conduct.
