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Tennessee v. Garner: The Landmark Supreme Court Case That Redefined Police Use of Deadly Force

In 1985, the United States Supreme Court handed down a landmark decision in the case of Tennessee v. Garner, which dramatically altered the legal landscape surrounding the use of deadly force by law enforcement officers. This case, which originated from a tragic incident in Memphis, Tennessee, set a precedent that continues to shape the way police officers are trained and held accountable for their actions. Tennessee v. Garner marked a significant turning point in the ongoing debate about police use of force and the protection of citizens’ constitutional rights.

The Incident

The case of Tennessee v. Garner revolved around the shooting death of Edward Garner, a 15-year-old African American male, on October 3, 1974. Officer Elton Hymon, a white police officer with the Memphis Police Department, responded to a report of a burglary in progress at a residence. Upon arrival, Officer Hymon observed Edward Garner, who was unarmed and had stolen a purse, attempting to flee the scene by scaling a fence. As Garner began to climb the fence, Officer Hymon made a split-second decision and shot him in the back of the head, killing him instantly.

The Legal Challenge

Following Edward Garner’s tragic death, his father filed a lawsuit against the Memphis Police Department, alleging that the use of deadly force against his unarmed son violated the Fourth Amendment of the United States Constitution. The Fourth Amendment protects citizens from unreasonable searches and seizures and requires that law enforcement officers have probable cause to use force.

The central issue in Tennessee v. Garner was whether the use of deadly force to apprehend a fleeing suspect, who was not an immediate threat to the officer or others, was constitutionally permissible under the Fourth Amendment.

The Supreme Court’s Ruling

In a groundbreaking decision, the Supreme Court ruled in favor of the Garner family, asserting that the use of deadly force to prevent the escape of a fleeing suspect is only justifiable when the officer has probable cause to believe that the suspect poses a significant threat of death or serious physical harm to the officer or others.

This ruling effectively struck down the common law “fleeing felon” rule, which had previously allowed law enforcement officers to use deadly force to apprehend any fleeing felon, regardless of the circumstances. The Supreme Court’s decision in Tennessee v. Garner set a new standard for the use of deadly force by police officers, requiring a careful assessment of the threat posed by the suspect.

Impact on Policing

Tennessee v. Garner had a profound and lasting impact on policing in the United States. It established a clear legal standard that officers must adhere to when deciding whether to use deadly force. Officers were now required to consider the severity of the crime committed by the suspect, the level of danger they posed, and whether there were any less-lethal alternatives available before resorting to lethal force.

This decision also emphasized the importance of de-escalation techniques and the preservation of human life, promoting the idea that lethal force should be a last resort. It prompted law enforcement agencies across the country to revise their use of force policies and invest in training officers to make more informed and judicious decisions in high-stress situations.


Tennessee v. Garner stands as a pivotal moment in the ongoing debate over police use of force and the protection of citizens’ constitutional rights. This landmark Supreme Court case redefined the boundaries of when deadly force could be used by law enforcement officers, emphasizing the need for proportionality and reasonableness in their actions. While it did not eliminate all instances of controversial police shootings, it set a standard that continues to guide discussions, policies, and training in policing to this day, ultimately striving to make encounters between law enforcement and citizens safer and more just.

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