Page 75 - Original 2020 Legal Guide By Jack Ryan
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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.
•
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