The U.S. Supreme Court held that courts may consider events before and throughout a police encounter, not only the precise instant a shot is fired, when assessing whether an officer’s use of force was objectively reasonable, the court said during a Term podcast discussion.

The ruling clarifies how Graham v. Connor’s objective-reasonableness standard should be applied: courts must examine the totality of the circumstances, which can include the events that led up to the use of force, although the decision did not adopt a categorical rule about which antecedent factors can be considered or whether officer conduct that contributed to danger may be excluded.

The case arose from a traffic stop in the Houston area on April 28, 2016. Officer Roberto Felix Jr. pulled over a vehicle for unpaid toll violations and asked driver Ashton Barnes for identification and proof of insurance. Barnes opened the driver’s door but did not exit, then restarted the car while the officer was still at the door; Felix unholstered his gun and, after jumping onto the door sill, fired two shots into the vehicle within roughly two seconds, one of which struck Barnes. Barnes was dead by the time backup arrived.

The Supreme Court emphasized that traffic stops are often dangerous and that officers make rapid, spur-of-the-moment decisions; those realities justify some deference to officers’ perceptions in assessing reasonableness. But the court rejected a rule that confines review strictly to the single instant an officer used force and confirmed that a reviewing court may look backward and forward in time to evaluate the objective reasonableness of the officer’s actions.

"You don't look just at that moment," Laurie Levinson said on the Federal Judicial Center podcast. "It's not limited just to the moment of the use of force, that you could look at time before it and throughout it to make that decision." Evan Lee noted the decision is narrow on its face but said it leaves for later proceedings the harder question of whether courts can discount officer conduct that contributed to the danger before the shooting.

The narrow holding will affect civil-rights suits brought under the Fourth Amendment arising from police encounters: lower courts must apply the Graham framework while allowing consideration of the broader sequence of events, and trial courts on remand will need to decide how much of the preceding conduct is relevant and admissible. The decision does not prescribe a single formula for that determination.