## Facts

- Police attempted to arrest Israel Leija Jr. on a warrant; he fled and led officers on an approximately 18-minute high-speed chase at about 85–110 mph.
- During the chase, Leija twice told a dispatcher he had a gun and would shoot police if they did not stop pursuing him; a report suggested he might be intoxicated.
- Officers positioned tire spike strips ahead; Deputy Ducheneaux deployed spikes on the roadway beneath an overpass.
- Trooper Chadrin Lee Mullenix went to the overpass and decided to shoot at Leija’s vehicle to stop it before it reached Ducheneaux, whom he believed was in danger.
- Mullenix radioed his plan; his supervisor instructed him to “stand by” and see if the spikes worked first, but whether Mullenix heard the instruction was disputed.
- As Leija approached, Mullenix fired six rifle shots from the overpass; Leija’s car then hit the spikes, crashed, and rolled. Four bullets struck and killed Leija; none struck the car’s radiator, hood, or engine block.
- Leija’s family sued under 42 U.S.C. § 1983 alleging Fourth Amendment excessive force; the district court and Fifth Circuit denied qualified immunity; the Supreme Court reversed.

## Issues

1. Whether clearly established law, as of March 2010, put it beyond debate that shooting at a fleeing suspect’s vehicle under these chase circumstances violated the Fourth Amendment, thereby defeating qualified immunity.

## Decision

- The Supreme Court reversed the Fifth Circuit and held Mullenix was entitled to qualified immunity.
- The Court assumed, without deciding, that the shooting could amount to a Fourth Amendment violation and decided only the “clearly established law” prong.
- The Court held existing precedent did not clearly prohibit Mullenix’s conduct in the specific context of an armed, threatening suspect engaged in a dangerous, high-speed chase and nearing an officer positioned by spike strips.

## Legal Principles

- Qualified immunity bars damages unless existing precedent places the constitutional question “beyond debate.”
- The “clearly established” inquiry must be particularized to the facts; general propositions about excessive force are insufficient.
- In assessing clearly established law for force used to end a dangerous car chase, courts must compare fact-specific precedents rather than rely on high-level standards.
- The Fourth Amendment does not require officers to select the least intrusive alternative; the question is whether the chosen action was clearly unlawful under then-existing law.

## Conclusion

The Court concluded that no precedent clearly established that firing at a fleeing suspect’s car from an overpass—during a high-speed chase involving threats to shoot police and imminent contact with another officer—was unconstitutional beyond debate, so qualified immunity applied.


Mullenix v. Luna, 136 S. Ct. 305 (2015)