## Facts

- A Texas law-enforcement officer stopped a rental car driven by Ashtian Barnes after a radio alert about outstanding toll violations.
- During the stop, Barnes searched for documentation; the officer claimed to smell marijuana, but no drugs were found.
- Barnes opened the trunk from the driver’s seat and turned off the ignition; shortly thereafter, the officer ordered him to exit while placing a hand on his holstered gun.
- Barnes opened the door but did not immediately exit; the car began moving forward.
- The officer drew his gun, stepped onto the car’s doorsill as it moved, and fired two shots into the vehicle within seconds; Barnes died at the scene.
- A firearm was later found in the glove compartment; no criminal charges were brought against the officer.
- Barnes’s mother sued under 42 U.S.C. § 1983, alleging Fourth Amendment excessive force.
- The district court and Fifth Circuit granted and affirmed summary judgment for the officer, applying a “moment-of-threat” rule that focused only on the two seconds when the officer clung to the moving car and treated earlier events as irrelevant.

## Issues

1. Whether a Fourth Amendment excessive-force analysis may be limited to the instant the officer perceives a threat, excluding earlier events (“moment-of-threat” doctrine).
2. Whether the Fourth Amendment instead requires evaluating the objective reasonableness of force under the totality of the circumstances, including relevant lead-up conduct.

## Decision

- The Supreme Court unanimously vacated the Fifth Circuit’s judgment and remanded.
- The Court held the Fifth Circuit’s “moment-of-threat” rule improperly narrowed the Fourth Amendment inquiry.
- Courts must apply an objective-reasonableness standard that considers the totality of the circumstances and does not impose a temporal cutoff.
- The Court did not decide whether the shooting was constitutionally reasonable; it required reconsideration under the correct standard.

## Legal Principles

- Excessive-force claims arising from stops or arrests are governed by Fourth Amendment objective reasonableness.
- Objective reasonableness requires consideration of the totality of the circumstances surrounding the seizure.
- The totality-of-circumstances inquiry has no time limit; relevant events leading up to the use of force may be considered.
- A rule that categorically excludes pre-shooting events from the analysis is inconsistent with the Fourth Amendment.
- Considering lead-up conduct does not create a separate “provocation” claim; it informs whether the ultimate use of force was objectively reasonable.

## Conclusion

The Court rejected a time-sliced approach to excessive-force claims and required lower courts to assess reasonableness by considering all relevant circumstances before and during the seizure, then remanded for application of that standard.


Barnes v. Felix, 605 U.S. 73 (2025)