Case Law Blog

United States v. Williams, No. 24-4512 (4th Cir. July 7, 2026) TL;DR Police received an anonymous 911 report that a light-skinned male with braids was sitting in a white Mercedes near an apartment-complex pool and “appears to be making drug transactions.” Two officers responded in separate marked police vehicles. The officers intended to make a voluntary encounter. But instead of parking in available spaces, they simultaneously stopped their patrol vehicles in the roadway, wi

Steger v. Willis, No. 25-6006 (6th Cir. July 21, 2026) TL;DR Police responded to a theft complaint and encountered the suspect standing behind an iron gate on his own front porch. The encounter became heated. The suspect refused to provide identification, told officers to get off his property, and ultimately yelled, “Fuck you!” at one of the officers. According to the plaintiff’s version of events—which the court was required to accept at the qualified-immunity stage—the offi

Hayat v. Diaz, No. 25-1235 (4th Cir. Aug. 20, 2026) TL;DR Police received a priority kidnapping call after an eyewitness reported seeing a man put three children into the trunk of a vehicle. Officers traced the vehicle to Fareed Hayat's home and approached him while he and his wife were outside. The encounter initially was consensual. But after officers questioned Hayat about the reported kidnapping, he refused to answer certain questions, prevented his wife from continuing t

Massimino v. Benoit, No. 25-1104 (2d Cir. Aug. 17, 2026) TL;DR The Second Circuit held that the First Amendment protects the right to record law enforcement activity in public, including publicly visible areas of a police station from a public sidewalk. But that did not mean officers were prohibited from investigating the person doing the recording. Recording a police station, standing alone, was not enough to establish reasonable suspicion. Here, however, additional circumst

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

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

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

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,

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

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

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

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

Chatrie v. United States, 609 U.S. ___ (2026) TL;DR The Supreme Court held that law enforcement conducts a Fourth Amendment search when it compels Google to disclose a user's historical Location History data through a geofence warrant. The Court concluded that individuals maintain a reasonable expectation of privacy in this highly detailed location information, despite Google's possession of the data. Importantly, however, the Court did not decide whether the geofence warrant

Sanchez v. Nunemaker, No. 25-50596 (5th Cir. June 23, 2026) TL;DR The Fifth Circuit held that a deputy was not entitled to qualified immunity after allegedly deploying a high-velocity pepper spray device directly into the eye of a handcuffed, seat-belted suspect from approximately half the manufacturer's recommended minimum safe distance. Although the suspect had been arrested for serious crimes and remained disruptive, the court emphasized that the constitutional analysis tu

United States v. Bolden, No. 25-1734 (7th Cir. June 12, 2026) TL;DR The Seventh Circuit upheld a search warrant even though the court acknowledged probable cause was a "close" question. Officers saw a convicted felon carrying a handgun into a residence, obtained a warrant, and recovered guns, drugs, ammunition, and over $50,000 in cash. The defendant argued the warrant lacked probable cause and contained misleading statements. The court sidestepped the probable cause issue an

Ward v. Brotzke, No. 25-1653 (6th Cir. June 12, 2026) TL;DR The Sixth Circuit held that Detroit police officers were entitled to qualified immunity after shooting a suspect who ignored commands, pulled a handgun from his pocket, and ran toward the exit of a convenience store. The court found that one officer who fired and missed never "seized" the suspect under the Fourth Amendment because the suspect continued fleeing. The officer who struck the suspect acted reasonably unde

United States v. Hemani, 608 U.S. ___ (2026) TL;DR The Supreme Court held that the federal government's prosecution of Ali Hemani under 18 U.S.C. § 922(g)(3)—the statute prohibiting firearm possession by unlawful users of controlled substances—violated the Second Amendment as applied to him. The government attempted to disarm Hemani solely because he admitted using marijuana several times per week, despite no evidence that he was intoxicated while possessing a firearm, danger

United States v. Evans, No. 25-1926 (8th Cir. June 9, 2026) TL;DR The Eighth Circuit upheld the conviction of a man who secretly recorded a 15-year-old girl bathing through a bathroom transom window. The court held that even if the suspect's initial consent to surrender his phone was questionable because an officer mentioned obstruction charges, the seizure was nevertheless lawful under the exigent-circumstances exception because officers had probable cause and a reasonable b

Martinez v. Hinojosa, (5th Cir. June 4, 2026) TL;DR The Fifth Circuit held that a police officer who mistakenly shot an innocent man during an active-shooter incident did not violate the Fourth Amendment because the officer's mistake was objectively reasonable under the circumstances. The court found that Officer David Hinojosa reasonably believed Jorge Martinez was the active shooter when Martinez emerged from a house carrying the suspect's rifle during an ongoing police gun

United States v. Debevec, (8th Cir. 2026) TL;DR Holding The Eighth Circuit affirmed the conviction of Jayden Debevec for attempted enticement of a minor under 18 U.S.C. § 2422(b), holding that sufficient evidence supported the jury's rejection of his entrapment defense and that the district court properly admitted evidence of internet searches suggesting an interest in minors. Even if admission of certain WhatsApp messages was error, it was harmless. Why It Matters This case