

A Hatchet, 25 Feet, and No Immediate Threat: Fourth Circuit Rejects Qualified Immunity in Fatal Shooting
Byers v. Painter (4th Cir. 2026) Citation: No. 25-1058 (4th Cir. Apr. 17, 2026) TL;DR Holding: Officer not entitled to qualified immunity at motion-to-dismiss stage for fatal shooting of armed but non-threatening suspect. Why it matters: Reinforces that possession of a weapon + noncompliance ≠ automatic deadly force—there must be a real, immediate threat. Key limit: Case is at the pleading stage—facts are viewed in plaintiff’s favor, and video must clearly contradict them to
3 min read


You Can’t ‘Divide and Conquer’ Reasonable Suspicion: SCOTUS Clarifies the Totality Rule in D.C. v. R.W
District of Columbia v. R.W. (2026) Citation: 608 U.S. ____ (2026) TL;DR Holding: Officers had reasonable suspicion to stop a driver where (1) a dispatch reported a suspicious vehicle, (2) passengers fled upon police arrival, and (3) the driver immediately attempted to leave with a door still open. Why it matters: The Supreme Court reinforces that courts must evaluate reasonable suspicion using the totality of the circumstances—not by isolating and discarding individual facts
3 min read


