Tennessee v. Garner Case Brief Summary | Law Case Explained
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Tennessee v. Garner | 471 U.S. 1 (1985)
Police officers’ use of deadly force against unarmed suspects is an intensely debated issue today, but the courts have been contending with this issue for decades. In the nineteen eighty-five case of Tennessee versus Garner, the Supreme Court first addressed the question of whether such deadly force violates the Fourth Amendment.
Edward Garner, who was 15 years old and around 5 feet, 5 inches tall, burglarized another person’s home at night. A neighbor called Memphis police officers to report the burglary. One of the officers went to the backyard and saw Garner run from the back door to the fence. The officer ordered Garner to stop, but Garner started to climb the fence to escape. Despite not seeing a weapon on Garner, the officer fatally shot Garner. A Tennessee statute authorized police officers to use all means necessary to capture a fleeing felon who refused to comply with an officer’s order to stop. The Memphis Police Department specifically had trained its officers that they could shoot a fleeing burglar who refused an officer’s command to stop.
Garner’s father filed a civil rights lawsuit against the officer, the City of Memphis, and its police chief and mayor, seeking money damages. The elder Garner alleged that the officer, who acted pursuant to departmental policy, violated the Fourth Amendment by fatally shooting the younger Garner when he posed no threat to the officer or the public. A federal district judge dismissed the lawsuit against all defendants, holding that the officer, who acted consistently with the Tennessee statute, didn’t violate the Fourth Amendment.
On appeal, the United States Court of Appeals for the Sixth Circuit concluded that the officer violated the Fourth Amendment but held that he and the other individual defendants were shielded from liability for money damages under the qualified immunity doctrine based on the state statute. However, the Sixth Circuit reversed the district court’s judgment in favor of the city and remanded for the district court to address whether a municipality could claim qualified immunity. On appeal, the State of Tennessee intervened to defend the state statute upon which the city’s policy was based. After their loss in the Sixth Circuit, the state and city sought review by the United States Supreme Court.
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