

Deadly Force on a Fleeing Armed Suspect — When “Armed” Isn’t Enough
Ruffin v. Davis (4th Cir. 2026) Docket Number: 25-1318, April 29, 2026 TL;DR Holding: The Fourth Circuit held that an officer is not entitled to qualified immunity when he uses deadly force on a fleeing suspect—even an armed one—who does not make a threatening or furtive movement with the weapon. Why it matters: This is a major reaffirmation (and tightening) of Tennessee v. Garner + Graham v. Connor: Being armed + running + ignoring commands still does NOT justify deadly forc
3 min read


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


