Tennessee v. Garner
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| Tennessee v. Garner | |
|---|---|
| Litigants | State of Tennessee v. Edward Garner |
| Decided | June 25, 1985 |
| Citation | 471 U.S. 1 |
| Court | Supreme Court of the United States |
| Majority | Anthony M. Kennedy |
| Joined | William J. Brennan, Thurgood Marshall, Harry A. Blackmun, Lewis F. Powell Jr. |
| Dissent | Byron R. White |
| Laws | Fourth Amendment |
Tennessee v. Garner was a landmark 1985 decision of the Supreme Court of the United States that constrained police use of deadly force against fleeing suspects under the Fourth Amendment to the United States Constitution. The ruling reversed a ruling by the Tennessee Supreme Court and established a constitutional standard applied in subsequent cases and statutes, influencing law enforcement training, municipal ordinances, and litigation strategies across the United States. The opinion, authored by Justice Anthony M. Kennedy, balanced claims advanced by the American Civil Liberties Union, civil rights litigators, and police unions against precedents from cases such as Graham v. Connor and earlier Fourth Amendment doctrine from Terry v. Ohio and United States v. Robinson.
Background
The case arose from a shooting in Memphis, Tennessee in 1974 in which Memphis police officers shot and killed a 15-year-old named Edward Garner while he fled a suspected burglary. The officers acted under a Tennessee statute authorizing the use of deadly force to apprehend fleeing felons. Litigation involved the Shelby County Sheriff's office, local prosecutors, and civil rights organizations. The initial civil action proceeded through the United States District Court for the Western District of Tennessee and the United States Court of Appeals for the Sixth Circuit, with involvement from amici including the National Association for the Advancement of Colored People and the National Rifle Association of America opposing different aspects of the statutory scheme.
Supreme Court Decision
On June 25, 1985, the Supreme Court of the United States held that the use of deadly force to prevent the escape of an unarmed, non-dangerous fleeing suspect was an unreasonable seizure under the Fourth Amendment to the United States Constitution. The majority opinion, written by Justice Anthony M. Kennedy, rejected a categorical rule that allowed deadly force whenever necessary to apprehend a fleeing felon and instead required a case-by-case assessment. Justices William J. Brennan Jr., Thurgood Marshall, Harry A. Blackmun, and Lewis F. Powell Jr. joined the majority. A dissent was filed by Justice Byron R. White, joined in part by Chief Justice Warren E. Burger and Justice William Rehnquist.
Legal Reasoning and Standard
The Court applied the Fourth Amendment's reasonableness test and drew on precedents including Terry v. Ohio and Graham v. Connor to articulate a standard: deadly force may not be used unless the officer has probable cause to believe the suspect poses a significant threat of death or serious physical injury to the officer or others. The opinion referenced notions of "seizure" under Fourth Amendment jurisprudence and balanced the interests of individual liberty against public safety interests asserted by state legislatures such as the Tennessee General Assembly. The Court emphasized that statutory authorizations for force, like the Tennessee felony escape statute, must comply with constitutional constraints identified in cases such as Mapp v. Ohio, Chimel v. California, and Katz v. United States in shaping reasonableness analysis.
Impact on Policing and Use-of-Force Policy
Following the decision, municipal governments, police departments, and state legislatures revised manuals, training curricula, and statutes. Agencies including the Federal Bureau of Investigation, the United States Department of Justice, and local police academies in cities such as New York City, Los Angeles, Chicago, and Philadelphia incorporated the Garner standard into use-of-force policies. Labor organizations including the Fraternal Order of Police and civil rights groups like the NAACP Legal Defense and Educational Fund clashed over operational guidance. Courts and administrative bodies used the decision to evaluate internal affairs investigations, civil liability under 42 U.S.C. § 1983 claims, and indemnification decisions by municipalities such as New Orleans, Detroit, and Baltimore.
Subsequent Developments and Litigation
Tennessee v. Garner was later interpreted alongside Graham v. Connor (1989), which extended objective reasonableness analysis to all excessive-force claims. Lower federal courts grappled with Garner in cases involving vehicular pursuits, canine deployments, and no-knock entries in jurisdictions like the Eleventh Circuit, Second Circuit, and Ninth Circuit. State supreme courts in California, Texas, Florida, and New York adapted tort standards and criminal statutes. Legislative responses included model policies from the International Association of Chiefs of Police and statutory amendments in states such as California, Oregon, and Minnesota that codified limitations on deadly force.
Scholarly and Public Reaction
The ruling generated extensive commentary in law reviews at institutions like Harvard Law School, Yale Law School, Columbia Law School, and Stanford Law School and debate in journals including the Harvard Civil Rights–Civil Liberties Law Review and the University of Chicago Law Review. Scholars such as Akhil Reed Amar, Cass R. Sunstein, and Gerald A. Gunther analyzed constitutional text, originalist arguments, and pragmatic policing consequences. Public responses ranged from municipal protests to endorsements by civil liberties organizations and criticism from some police leadership and conservative commentators. The enduring significance of the decision appears in litigation involving use-of-force controversies in cities like Ferguson, Missouri, Baltimore, Maryland, and Minneapolis, Minnesota and in continuing debates in the United States Congress over federal oversight and criminal justice reform.