Tennessee v. Garner
"Tennessee v. Garner" is a landmark Supreme Court case stemming from an incident in 1974 involving a fifteen-year-old boy, Edward Garner, who was shot by a police officer while fleeing from an attempted burglary. The officer acted under Tennessee's fleeing felon statute, which permitted the use of deadly force to apprehend suspected felons. However, the circumstances of the case raised significant questions about the reasonableness of such force, particularly against an unarmed and seemingly non-threatening individual. The Supreme Court ultimately ruled by a 6-3 majority that the application of deadly force in this context violated the Fourth Amendment's protection against unreasonable seizures. Justice Byron R. White emphasized that the use of lethal force is only justified when a suspect poses an immediate threat to the safety of law enforcement or others. This decision led to a reevaluation of similar laws across numerous states, highlighting the necessity for restraint in police use of force, especially regarding non-dangerous suspects. "Tennessee v. Garner" remains a crucial reference point in discussions about police practices and civil rights in the United States.
Tennessee v. Garner
Date: March 27, 1985
Citation: 471 U.S. 1
Issue: Use of force by the police
Significance: The Supreme Court held that a police officer may use deadly force only when there is probable cause to believe that the suspect poses an immediate threat of death or physical harm to the officer or to others.
In 1974 a fifteen-year-old boy, Edward Garner, broke a window to enter an unoccupied house in Memphis, Tennessee. Two officers intercepted the suspect in the back of the house. By shining a flashlight, the officers were “reasonably sure” that the suspect was young and unarmed. When he was about to escape over a fence, one of the officers shot him in the back. The officer had acted in accordance with Tennessee’s fleeing felon statute, which authorized all means necessary to stop a suspected felon. The decedent’s father, nevertheless, won a damage award against the officers and the city.
By a 6–3 vote, the Supreme Court struck down the relevant portion of the Tennessee law. In the majority opinion, Justice Byron R. White wrote that apprehending a suspect “is a seizure subject to the reasonableness requirement of the Fourth Amendment.” The majority found no reasonable justification for officers to use deadly force against a suspect who did not appear to be armed and dangerous. After the Garner decision was issued, half of the states had laws that were unconstitutional because of a lack of restraint on the use of force while attempting to arrest a nondangerous suspect.
Bibliography
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