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Case Law Blog


Officers Don't Lose the Automobile Exception Just Because They Could Have Gotten a Warrant
United States v. Randle, No. 25-2278 (7th Cir. July 29, 2026) TL;DR The Seventh Circuit held that officers who had already developed probable cause through a controlled drug investigation were authorized to search a suspect's vehicle under the automobile exception—even though they had enough time beforehand to obtain a search warrant. The court also reaffirmed that a properly conducted traffic stop is not unlawfully prolonged when officers continue working on the traffic miss
3 days ago4 min read


A K-9 Alert Doesn't Become Invalid Just Because No Drugs Are Found: U.S. 7th Cir. Affirms Firearm Conviction
United States v. Banks, No. 24-2227 (7th Cir. June 30, 2026) TL;DR The Seventh Circuit upheld a firearm conviction after rejecting multiple Fourth Amendment challenges arising from a traffic stop. The court held that officers had reasonable suspicion for the initial stop, did not unlawfully prolong the detention while the driver attempted to obtain updated insurance information, and lawfully searched the vehicle after a certified drug-detection dog alerted—even though no narc
Jul 255 min read


Pennsylvania Rejects the Open Fields Doctrine: State Supreme Court Holds Warrantless Searches of Posted Private Land Violate the State Constitution
Punxsutawney Hunting Club, et al. v. Pennsylvania Game Commission, No. 23 WAP 2023 (Pa. July 21, 2026) TL;DR In one of the most significant Fourth Amendment-related decisions of 2026, the Pennsylvania Supreme Court held that Article I, Section 8 of the Pennsylvania Constitution does not permit warrantless searches of posted or enclosed private lands under the federal Open Fields Doctrine. In doing so, the court expressly overruled its 2007 decision in Commonwealth v. Russo an
Jul 226 min read


53 Taser Cycles, Neck Restraint, & Death: 10th Cir. Rejects Monell Claim Despite Criminal Conviction of Officers
Lakey v. Bryant, No. 25-7068 (10th Cir. July 7, 2026) TL;DR The Tenth Circuit affirmed judgment in favor of an Oklahoma sheriff following the death of Jared Lakey, who died after being tased 53 times over approximately nine minutes by municipal officers before an assisting sheriff's deputy applied a lateral vascular neck restraint (LVNR). Although the individual municipal officers were ultimately found civilly liable for excessive force and guilty in the criminal proceeding,
Jul 196 min read


Split-Second Decisions and Qualified Immunity: Fifth Circuit Affirms QI Despite No Time to Comply with Commands
Searles v. City of Houston, No. 25-20383 (5th Cir. July 9, 2026) TL;DR The Fifth Circuit affirmed qualified immunity for a Houston police officer who fatally shot a felony suspect less than two seconds after ordering him to "show me your hands." Although the court acknowledged the suspect had essentially no opportunity to comply with the command, it held that no clearly established law prohibited the officer's actions under the highly specific facts confronting him. The Fact
Jul 165 min read


When a TASER Becomes Deadly Force: A $100 Million Mistake
The Eleventh Circuit reminds officers that it's not always the weapon—it may be the environment that determines whether force is constitutionally "deadly." Over the past decade, courts have routinely described conducted energy weapons (CEWs), commonly referred to as TASERs, as intermediate force, not deadly force. That classification has shaped countless use-of-force decisions and training programs. But as every use-of-force instructor knows, no force option exists in a vacuu
Jul 125 min read


When Mental Illness Meets an Active Shooter: The Fourth Circuit Draws the Line on ADA Liability
Morgan v. City of Charlotte, No. 23-1748 (4th Cir. June 29, 2026). TL;DR The Fourth Circuit affirmed summary judgment for officers who shot a mentally ill man after he repeatedly threatened neighbors, fired what appeared to be a real handgun into a residential neighborhood, and refused commands to disarm. The court held that the use of deadly force was objectively reasonable under the Fourth Amendment and that the City did not violate the ADA because officers made reasonable
Jul 85 min read


Knock, Announce... But Don't Expect Suppression: Florida Supreme Court Rewrites Search Warrant Law
State v. Times, No. SC2024-0647 (Fla. June 25, 2026) TL;DR In a major shift in Florida search-and-seizure law, the Florida Supreme Court held that evidence will no longer be suppressed solely because officers violate Florida's statutory knock-and-announce requirement while executing a valid search warrant. In doing so, the Court expressly overruled its 2010 decision in State v. Cable, aligning Florida with the United States Supreme Court's decision in Hudson v. Michigan. Why
Jul 53 min read
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