Research Paper The Use of Deadly Force

Research Paper The Use of Deadly Force

ResearchPaper: The Use of Deadly Force

Theuse of deadly force in the Unites States has remained a topic of hotdebates for a long period (Alpert and Smith, 1994). The use of deadlyforce in this country is married to the words license to kill. Thepolice often use deadly force in line of their work to stop crime. On the other hand some civilians use the force to commit all forms ofcrime such as murder, burglary, rape, to name but a few (Tam andSreenivasan, 2014). Deadly force can be argued from either the lawenforcement point of view or the civilian side of the society. Thereviewed court cases in this paper reveal the contradicting opinionson the use of deadly force. From most of the court cases reviewed, itis obvious that the police are given the right to make the decisionon when to take a suspect’s life. According to Martinez, the law onthe use of force should be revealed because many factors should beput under consideration before a human life is taken by the police(2015).

Arecent study by Bulman (2011) argues that the use of deadly force inthe United States has impacted even on child development. Thechildren are being born into a society in which almost every personpossesses a gun. The movies and social media platforms such asYouTube are impacting so much on their growth. The culture has taughtthe children and the youth that use of guns is a usual act, and it isclear that many youths will not think twice when given a chance touse a gun. There is enough evidence from past studies on this topicthat the United States is one of the cultures in which crime rateespecially gun-related is on the rise. The police are trainedpersonnel, who provide security and protect people`s lives. However,the various cases reviewed in the case study will show that contraryto their responsibility, some police use deadly force and end uptaking the lives of the people they are supposed to be safeguarding.

TheUnited States is one of the country`s in which individuals are givena right to own a firearm. Possession of firearms by civilians wasincorporated into law through the Fourth Amendment of the UnitedStates Constitution. According to Coppolo, the change gives a personthe right to carry or possess a firearm in most states in the US(2008). Research indicates that many people not only in the US butall over the world think that guns are meant to kill persons in anact of self-protection. The review of several cases discussed in thecase study support the argument that many people think that many ofthe people who are killed as a result of the use of deadly force arepeople believed to be armed and dangerous to the public and thepolice. Up to date, there are contradicting arguments on whether gunskill people or people use guns to kill (Adler, 2007). According toTam and Sreenivasan (2014), there are many instances that civiliansand police officers sustain injuries or even lose their lives, andthe term deadly force is used to get away with violated human rights.Some of the cases reviewed in this case study reveal many are thetimes police officers are granted immunity by the court having useddeadly force in violating a civilian’s human rights.

Accordingto Bulman (2011), the adverse impacts of deadly force on the societycan be eliminated if the police embraced the use non-lethal force.Bulman argues that use of non-lethal ammunition would significantlyreduce the fatality rate as a result of deadly force. For instance,in the military specifically the Marine Corps are not authorized tocarry any weapons on base. Marine have the skills and adequatetraining on how to kill using firearms. One of the strategies themilitary use to prevent misuse of weapons is the rule to return allthe weapons into the armory to the battalion. The constitution alsorequires some amendments especially on possession of guns bycivilians, to ensure the observation of more strict regulations inlicensing a civilian to own a gun.


Theuse of deadly force is impacting negatively on our today’s society.The use of deadly force has taken the lives of many people includingthe police, civilian men and women, youths and even children. In theUnited States, much is yet to be done in regulating the use of deadlyforce by the police.

Justificationof the study

Theuse of deadly force has been a topic of hot debates for a long timein the United States. The current study is significant since it willreveal facts on how the use of deadly force is impacting on theAmerican society as a whole. The data gathered from the study will beuseful in finding appropriate strategies to eliminate the use ofdeadly force. Elimination of deadly force is significant because itwill not only reduce the crime rate in the country but will alsopreserve the lives of many people. Many people who are accidentlykilled through the use of deadly force lack the chance to reach theirmaximum potential in terms of development, meaning the country as awhole also lacks the opportunity for more development.


Thecurrent study is a qualitative research aimed at investigating thehuman behavior on the use of deadly force. Use of deadly force ishuman behavior that has been mainly observed among the police.However, current research indicates that, in the United States thehabit has become common even among the civilians especially the youngpeoples. Qualitative research is useful in understanding humanbehavior, and hence the results of this study will offer a betterunderstanding on the issue of the use of deadly force.


Theresearch utilized a case study as the research design. A case studyis defined as an in-depth study of a particular phenomenon, ratherthan a broad survey covering several issues. The case study aimed atreviewing several court cases related to use of deadly force. Casestudies are effective in revealing in-depth information about humanbehavior such as the use of deadly force. The case study covered 12court cases involving the police and civilians in the United States.

Datacollection methods

Forthis research, archival data collection method was utilized. Archivaldata is the information that already exist in files (eitherindividual’s, agent’s or organization’s files). This method ofdata collection was found to be the most appropriate for this studysince it is convenient in terms of time and finances. Online journalarticles and other internet sources covering various courts casebriefs on the use of deadly force were analyzed in detail. Out of thecourt cases, 12 of them were incorporated into the case for moredetailed analysis to reveal useful information on the topic underinvestigation.

Analysisof the 12 federal Court’s Cases Appeals

  1. Acoff v. Abston, 762 F.2d 1543 (11th Cir. 1985)

Inthis case, a civilian Acoff Lewellyn appealed to the court for asecond hearing after he felt that his constitutional rights wereviolated. Acoff accused D.E. Abston and J.T. Reed, police officers ofhaving violated his constitutional rights by inflicting injuriesthrough the use of unnecessary force. He claimed that under theamendments to the U.S. Constitution, his rights were violated anddemanded compensation and disciplinary action taken against the twopolice officers. However, the judge ruled in favor of the policeofficers stating that the two are granted immunity by the law andthat their actions were reasonable at the time of the shooting.

  1. Tennessee v. Garner 471 US 1, 105 S.Ct. 1694, 85 L.Ed.2d 1 (1985).

EltonHymon, a police officer, shot and took the life of an alleged robberby the name Edward Garner as he fled from the crime scene. It wasdiscovered later that Garner was not armed at the time of theshooting and that Hymon was reasonable aware of that fact. After hisdeath, his family members filed a case against the police officerclaiming that the use deadly force had violated Garner`sconstitutional and human rights. However, the plaintiff lost the caseand in his ruling, the judge stated that the police officers have theright to use their guns to prevent the escape of a person posingthreat of death to the public.

  1. Dodd v. The city of Norwich, 827 F.2d at 7 (1987)

Acivilian, Velma Dodd appealed for another hearing, seeking justicefor the damages and loss of her son Dwayne Dodd. Dwayne died aftergetting shot by a relief police officer Eric Larson while strugglingfor the officer`s gun at the time of arrest. The plaintiff arguedthat the city of Norwich and officer Larson violated Dwayne’srights since he was not armed at the time of his arrest. However,even after the appeal, the court ruled in favor of the defendant. Thejudge stated that that the police officer was reasonable to shootDwayne to prevent him from snatching his gun since he would posethreat of death to him and the public.

  1. Cameron v. City of Pontiac, Mich., 813 F. 2d 782 -(1987).

In1983, a suspected thief, Cameron was run over by a speeding vehicleas he tried to flee from the police officers who were in hot pursuitand shooting at him. April 1985, Cameron’s mother filed a caseagainst the City and officers McBride and Roberts for having useddeadly force in attempting to arrest his son, leading to his untimelydeath. However, the case was dismissed by the district court on 27thDecember 1985. The plaintiff appealed for a second hearing but againthe judge ruled in favor of the defendants stating that policeofficers have the immunity and the right to use force in preventing afelon from escaping.

  1. Drewitt v. Pratt, 999 F.2d 774, 779-80 (4th Cir.1993)

Drewittsustained injuries when Officer Fred L. Pratt tried to arrest him forcareless driving. Drewitt, who had sustained two gun shots butsurvived from the incident, filed a case against Pratt claiming thathe had violated his rights as constituted in the fourth andfourteenth amendments to the US constitution. The plaintiff alsoaccused the officer of assault, battery, and negligence. Even afterappealing, the court dismissed the case on the grounds that OfficerPratt was reasonable to use deadly force for self-protection andprevent Drewitt from causing more threats of death to innocentpedestrians and the general public.

  1. Estate of Starks v. Enyart, 5.3d 230, 234 (7th Cir.1993)

November1st,1989, Starks stole a taxicab, and three officers sought after him.When the three officers surrounded starks, he refused to submit andinstead tried to escape. Immediately, all the three officers openedfire and killed him on the spot. Starks’ family members filed acase in the district court accusing the officers of having violatedStark’s civil rights. The court ruled in favor of the threeofficers based on the fact that the three qualified immunity defense.Even after an appeal, the plaintiff still lost the case, with thejudge stating that the officers were reasonable use deadly force tostop the suspect from escaping.

  1. Ellis v. Wynalda, 999 F.2d 243, 247 (7th Cir.1993)

StevenEllis broke into an unoccupied pharmacy in Indianapolis on September7th,1986, and stole drugs and some money. Wynalda, the officer, alertedto go the scene met the suspect in the building’s courtyard andordered him to halt. However, Ellis tossed the bag containing thestolen materials and tried to escape. The officer fired and shot thesuspect in the back despite the fact that he reasonably was awarethat Ellis was unarmed. Just like in other similar cases, thedistrict court ruled in favor of the officer and after appealing theplaintiff lost the case again because Wynalda qualified immunity.

  1. Scott v. Henrich, 39 F.3d 912, 915 (9th Cir.1994).

Underthis appeal, a woman accused police officers of using deadly tryingto comprehend his husband Scott living him dead. Having beensuspected of drug trafficking, the police tracked Scott back to hishome and shot him twice in his car when he showed signs of reachingfor a weapon. Before dying, Scott had uttered the words (they shouldhave identified themselves as police officers) to his wife, theattending doctor and the police officers

  1. Scott v. Henrich, 39 F. 3d 912 (9th Cir. 1994).

Awoman appeals for a second hearing on the dismissal of her caseagainst the municipality and police officers who shot and killed hishusband, Scott. The plaintiff argued that the officers should haveused alternative ways of approaching Scott. According to the lateman’s widow, the police officers used deadly force that left hishusband dead. However, the plaintiff lost the appeal on the groundthat the officers qualified immunity and that they acted reasonablyduring the time of arrest.

  1. Vaughan v. Cox, 343 F.3d 1323 (11th Cir. 2003).

Thisis an appeal in which the plaintiff raises several claims that hesuffered injuries inflicted by police officer Cox, at the time ofarrest. The plaintiff argues that the district court erred in theirruling since under the fourteenth amendment of the US constitution,Cox`s actions violate his civil rights. He claims that even though hewas not subjected to seizure, Cox used unnecessary force in arrestinghim living with severusely injured. The plaintiff lost the appeal onthe basis that Cox`s actions were reasonable and that he qualifiedimmunity.

  1. Scott v. Edinburg, 346 F. 3d 752 -(2003).

Thisisanappeal in which family members filed a case against police officers,who shot and killed their brother Scott. Scott was shot by officerEdinburg at a gas station several times as he tried to steal anddrive away with officer`s car. From the testimonies of two affidavitsintroduced by the plaintiff in the district court, it was clear thatthere were no bystanders in the gas station when Scott tried toescape with the vehicle. Despite that fact, the officer fired at himtwice before the car exited the gas station, and few minutes laterScott died and the car crushed. It was not clear which shot killedhim, but the doctors who attended him argue that he might have diedout of the initial shots. The district court dismissed the casebecause the officer qualified immunity. Later the plaintiff lost theappeal on the basis that the officer was reasonable in using deadlyforce to prevent the felon from posing a threat to the public.

  1. Scott v. Harris, 550 US 372 (2007).

Thisis an appeal of a case in which Scott accuses police officer Harrisof having used deadly force at the time of arrest. Officer Harris andhis partner had received a call that a person whose descriptionmatched Scott had stolen a truck and was fleeing away. To force thevehicle off the road in speed car chase, Officer Harris fired shotsat the fleeing truck which unknown to him, left Scott injured. Theplaintiff claimed that the officer’s actions were unreasonableunder the fourth amendment to the US constitution. The Supreme Courtdismissed the case on the ground that it is reasonable for a policeofficer to use deadly force in stopping a dangerous high-speed carchase that poses threats to innocent bystanders. The appeal was alsodismissed because the officer was reasonable and hence qualifiedimmunity.

Discussionof the court cases analysis

Fromthe analysis of the 12 court case appeals, there are obviousquestions that an intelligent reader will ask:

  • Is the current legislature permitting the use of deadly force by police officers in arresting suspects?

  • Are the police officers licensed to kill because they qualify immunity?

  • When is it necessary to use deadly force?

  • Is it reasonable for police to use deadly force to prevent the escape of an unarmed felon?

Inall the 12 court cases appeals, it is clear that the police officersuse deadly force to prevent the escape of suspects, despite the factthat many of the suspects are unarmed at the time of arrest.According to Wansbrough (2008), the United States rule of law statesthat deadly force cannot be used to prevent a felon from escaping.However, the law explains that deadly force is necessary to stop theescape of a suspect if the officer believes that the suspect poses agreat danger of death or serious physical injuries to the officers orthe public. Looking at the Scott v. Edinburg, 346 F. 3d 752 -(2003),case it is clear that Officer Edinburg used deadly force inpreventing Scott from escaping with his car. The officer despite thefact that he was aware that Scott was unarmed, he went ahead andkilled him. In this particular case, Scoot did not pose anysignificant threat to the officer nor the bystanders but the officerwent ahead and shot him causing his death. It is sad that the currentlaw always protects the police on the basis of the reasonable act andqualified immunity. Alpert and Smith (1994) ask a disturbing questionthat the whole society needs its answer: how reasonable is thereasonable man?

Accordingto Adler (2007), the use of deadly force in police work is inevitablein some circumstances. In many cases, police officers are obliged touse deadly force to safeguard their lives and the lives of otherinnocent people. However, the author points that the necessity touse deadly force should not mean “shoot to kill” to many policeofficers who misuse power. From the review of the 12 court cases, itis clear that the police officers do not put into considerationsvarious factors influences the decision to use deadly force. Some ofthe factors that a police officer should consider before using deadlyforce include: is the use of deadly force reasonable? Am I trainedproperly to use deadly force? In case of improper use of deadlyforce, who is liable? According to Adler, if these factors are putinto considerations, the incidences of improper use of deadly forceby police officers will significantly reduce.

Arecurrent question that arises from the 12 court cases reviewed iswhether or not the police can use less intrusive forces whenarresting fleeing suspects rather than using deadly force? (Martinez,2015). However, from the ruling of almost all the court cases, it isclear that law enforcement officers are not obliged to use lessintrusive strategies under the fourth amendment to the U.S.constitution. The bill touches on issues concerning the use of lessintrusive means by law enforcement officers. The current lawexplicitly states that a police officer can reasonably use deadlyforce under some certain circumstances as stated earlier in thisdiscussion.

Leonnigpoints out that the justification for using deadly force is the mostimportant factor that a law enforcement officer should consider(2014). The Code of Criminal Procedure Texas of Texas clearlyindicates that a police officer is permitted to use all reasonablemeans t execute an arrest. However, the same Code Criminal Procedurefurther explains that no unnecessary force should be utilized in thearrest and detention of a suspect. The 12 court cases reviewed revealtangible evidence that many are the times law enforcement officerbreak this law, and the same law defends them before a court ofjustice.

In1995, the use of deadly force was approved and implemented by allpolice officers within the Department of Justice (Adler, 2007). Thepolicy states that &quotpolice officer is permitted to apply deadlyforce only when necessary. An officer is allowed to use deadly forceif he or she feels that it is reasonably necessary to use it toprevent the suspect from causing injury to the officer or a thirdparty.” However, the clause points out that deadly force usedshould not surpass what a realistic person would consider essentialto seize the suspect or shield an officer or third party. The currentlaw was drafted to protect citizens from the improper use of deadlyforce either by police or civilians. However, from the 12 court casesanalyzed, there is enough evidence to make the conclusion that thesame law seems to defend and encourage police officers in misusingdeadly force. Such observations have led to many researchers tryingto answer the research question: “When is it necessary for policeofficers to apply deadly force?” (Tam and Sreenivasan, 2014:Martinez, 2015).


Fromthe research carried out, there is more than adequate evidence thatthere needs to be a fresh look at the legislation on the use ofdeadly force. First and foremost, all the state legislatures shouldamend or change clauses touching on the use of deadly force by lawenforcement officers. According to Amnesty International report of2013, the law should be looked into carefully to ensure that theclauses that allow the use of deadly force are in line with the setstandards. The law states that a law enforcement officer shouldresort to deadly force in instances in which it is necessary toprotect against the threat of death or serious physical injury. There should be a creation of the national commission in charge ofNational Crime and Justice Task Force that should be tasked with theresponsibility of evaluating and implementing necessary changes topolicing issues. The establishment of such a commission will not onlyensure the legislature in the use of deadly force is actually appliedbut most importantly to prevent the improper use of lethal force(Amnesty International report, 2013).

Thereis a need for a legislative action to be taken to ensure that all lawenforcement officers comply with the restrictions to the use ofdeadly force as stated in international law and standards (O’Mara,2014). The current legislation should be amended to includerestrictions on the use of deadly force by police officers. O’Maraargues that the Congress should also pass laws that focus oneliminating the use of deadly force by law enforcement officers andto see to it that the laws are implemented (2014). The newlegislation and amendments to the current legislature would have amore positive effect on the society and stop many these senselesskillings. From the current law, some instances clearly require thelaw enforcement officers to apply deadly force and therefore, therecommended changes in the legislature will not eliminate the use ofdeadly force.

Onearea that clearly needs the use of deadly force such as shoot to killis when a person is protecting himself or another person from a fatalattack by an animal. In many countries, the military is tasked withthe responsibility of protecting citizens from terrorism. This is anarea that the military should apply deadly force since terrorismposes a great danger not only to individuals but a country as awhole. In some countries such as England, law enforcement officerssuch as the police are not authorized to carry firearms, not evenwhen on their patrol (shift). The society is an evolving unit, andthe United States need to evolve by learning from example fromcountries like England in managing the use of deadly force. There isno guarantee that the various recommended changes to the legislatureand new strategies will immediately amend the use of deadly force inthe country. However, the implementation of the amendments to thecurrent legislature will be a sign that the country is in the rightdirection in dealing with issues surrounding the national issue ofdeadly force.

Ina country like Italy, it is only the law enforcement officers who areauthorized to the police carry weapons. The citizens are notpermitted with an exemption of hunters who are allowed to own ariffle. The hunters in this country are required by law to registerthe riffle serial numbers with the police department in their townsof residence. Such laws restricting the use of deadly force bycivilians will significantly reduce instances in which deadly forceis used both by civilians and police officers. There should be rulesrestricting law enforcement officers from carrying a weapon when noton duty. From the 12 court cases reviewed in this paper, there areinstances when police officers have used their arms and caused eitherdeath or severe physical injuries, despite the fact the fact theywere off duty. Regulations on the possession of weapons by lawenforcement officers can substantially reduce the number of needlessdeaths of both the civilian and police officers.

Accordingto Adler (2007), if there are regulations restricting the civiliansfrom possessing weapons such as guns, then the police would have noreason to resort to deadly force during an arrest. It means that thepolice would be obliged to use other less intrusive and non-lethalmeans in apprehending suspects. There are many non-lethal ways andammunition that the police can utilize in detaining suspects such asthe use of rubber bullets, paintballs, tear gas, wooden blockshotguns, to name but a few. The listed ammunition can inflict painbut can cause death or irreversible physical injuries on suspects.The main challenge we have currently on the use of such non-lethalmeans is that many of the civilians are armed. Therefore, they canpose significant danger of death and serious physical injurydangerous to the police, being aware of the fact that they cannot bekilled. Therefore, apart from enacting laws that restrict civiliansfrom owning guns, there is the need for the government to createawareness among the citizens on the importance being unarmed.

Impactof the Thesis/Research on the Practice of Law

Thecurrent research has serious implications for the current law,especially on issues deadly force. There is adequate evidence fromthe paper that the current law has gaps that need to be filledurgently to resolve the issue on the use of deadly force. The primaryaim of creating and implementing the law is to safeguard the lives ofa country`s citizen. Therefore, if the same law as it has beenrevealed in this research contributes to the loss of lives ofthousands of civilians, then there is a great need for a fresh reviewof this law. The US Department of Defense has adequate resources,manpower and all that is required to put to an end the disturbingissue of deadly force.

Theinformation provided by this research is highly resourceful for useby the Congress, US Department of Defense and all other concerned lawenforcement authorities. If all the recommendations presented in thispaper are implemented, the current research will have a greatpositive impact on the practice of law in the United States. Theresearch has pointed out the need for various amendments to thecurrent legislature to restrict the use of deadly force both bypolice officers and the civilians. If the law is amended to restrictthe possession of guns by civilians, it means that the lawenforcement officers will need to apply less intrusive means inapprehending criminals. From the 12 court cases reviewed in thispaper, it is clear that many of the times the plaintiffs, who wereall civilians did not get the justice they were seeking from the law.Such painful truth should impact on the current legislature to ensurethat the law enforcement officers who use deadly force improperly aredisciplined accordingly hence reducing such instances.

Importanceof the Thesis/Research to the Writer

Thecurrent research is very important to me. For a long time, I havebeen asking myself the question:&quotare police officers authorizedto kill?&quot From the research, I think I have a clear answer as towhy many people think as I do that police officers have the authorityto kill. The research has enlightened me on the legislature factorsthat encourage police officers to use deadly force improperly. Thestudy has analyzed the current gaps in the law on the use of deadlyforce and how these gaps can be closed to put to an end thisdisturbing issue. The implementation of the recommendations presentedin this paper is critical to me since it will mean reduction in theuse of deadly force that has caused the death of thousands ofcivilians and police officers. I believe life is sacred and shouldnot be lost through improper use of deadly force. The currentresearch offers me some hope that there are strategies the USDepartment of Defense can implement to eliminate use of deadly force.Therefore, there is hope that the use of deadly force will come to anend and prevent the unnecessary deaths of many people before reachingtheir maximum potential.


Fromthe paper, it is clear that there are instances that the use ofdeadly force by law enforcement officers is inevitable. Suchinstances are: when an officer is preventing a felon from escaping,and the officer deems it reasonable to use deadly force to stop thecriminal from injuring the officer or a third party. However, theresearch indicates that many are the times when law enforcementofficers have applied deadly force improperly, causing deaths ofthousands of suspects. The current legislature is lacking in verymany ways, in ensuring the police comply with the rules on the use ofdeadly force as stated in the international standards of law. Thereis adequate evidence from the paper that many police improperly usedeadly force and get way with the misconduct on the grounds ofqualifying immunity and being reasonable.

Theresearch indicates that there is a lot to be done in terms ofamending the current legislature to deal effectively with the issueof the improper use of deadly force. The law should integrate moreclauses to restrict the use of deadly force by police officers.Furthermore, the US government should learn from examples from othercountries such as Italy on restrictions hindering civilians frompossessing weapons. The proposed amendments will not only reduce theuse of deadly force but will also significantly impact on the largersociety. Restrictions on the use of deadly force will resort to theuse less intrusive means by the law enforcement officers hencepreventing the deaths of many people who die before reaching theirmaximum potential. Therefore, it can be concluded that the currentresearch is a valuable resource to the US Department of Defense, toassist in amending the current law about the use of deadly force.


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