Associate
Overview of Barnes v. Felix
Today, the Supreme Court of the United States (SCOTUS) delivered an important decision in the case of Barnes v. Felix Barnes v. Felix, No. 23-1239, slip op. at 5-6, 2025 WL 1401083, (U.S. May 15, 2025). It took the opportunity to expand the legal landscape for evaluating police use of force based on its ruling prior ruling Graham v. Connor, 490 U.S. 386 (1989). This ruling is an excellent teaching tool for excessive force claims and how those claims should be framed to courts at the district level.
The Case at a Glance
The incident in question occurred on April 28, 2016, when Officer Roberto Felix, Jr. stopped Ashtian Barnes for alleged toll violations. During the stop, Barnes, who was driving a rental car, was unable to produce his license and began searching through papers. Officer Felix, suspecting marijuana, instructed Barnes to open the trunk. Barnes complied and turned off the ignition. However, when asked to exit the vehicle, Barnes restarted the car. In response, Felix jumped onto the car’s doorsill and, without clear visibility, fired two shots, fatally wounding Barnes. The entire episode, from the car’s movement to the shooting, unfolded in about five seconds. Barnes’s mother subsequently filed a lawsuit against Felix, alleging excessive force in violation of the Fourth Amendment.
What the Supreme Court Decided
In its decision, SCOTUS rejected the Fifth Circuit’s “moment-of-threat” rule, which focused solely on the instant an officer perceived a threat. Instead, the Court emphasized the need to evaluate the “totality of the circumstances,” including events leading up to the use of force. This broader approach aligns with longstanding legal principles but was reinforced by the Court’s explicit rejection of the segmented analysis previously applied.
Rejecting the “Moment-of-Threat” Rule
The Court stated, “The moment-of-threat rule applied below prevents that sort of attention to context, and thus conflicts with this Court’s instruction to analyze the totality of the circumstances.” The Court noted that the rule imposed “chronological blinders,” which hindered a comprehensive assessment of the events. The Court went on, “[E]arlier facts and circumstances may bear on how a reasonable officer would have understood and responded to later ones… [L]ater, ‘in-the-moment’ facts ‘cannot be hermetically sealed off from the context in which they arose.’ ”
This decision not only reaffirms the importance of context but also provides additional guidance on the application of the Graham v. Connor standard.
Why the “Chronological Blinders” Language Matters
Although the case originated in the Fifth Circuit, its implications extend to other jurisdictions, including the Ninth Circuit, when district judges put on chronological blinders in evaluating decisions that drive the use of force. The “moment-of-threat” or any analog that allows for intellectual compartmentalization of the decisions that drive the use of force must be rejected. The Court’s decision challenges this practice, emphasizing the necessity of considering the entire context of an incident.
The term “chronological blinders” used in the opinion is particularly noteworthy. It underscores the importance of presenting events in chronological order, a common practice in drafting civil rights complaints at our office.
This approach supports thorough investigations and challenges the strategic release of selective video footage by police departments, which can obscure the full context of an incident. Barnes reinforces the need for a holistic view of events, ensuring that justice is served in a fair and balanced manner.