Page 75 - North Carolina 2020 Legal Guide
P. 75

Task: Deadly Force: Pre-Shooting Tactics






          St. Hilaire v. City of Laconia, 71 F.3d 20 (1995).

               Officer conduct leading up to the need to use deadly force is being

               considered by some courts in the reasonableness analysis of the

               ultimate use of force.


          • Some circuits are considering whether the officer’s actions leading

               up to the need to use deadly force somehow created that need.

          • But see San Francisco County v. Sheehan, next page and County of

               Los Angeles v. Mendez following Sheehan.


          •
















                                     ©2020 Jack Ryan  Legal & Liability Risk Management Institute                                    74
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