SCOTUS: Barnes v. Felix

Trigger Warning: The following case includes depictions of graphic violence. Please read at your own discretion.

In our recent AP Government and Politics class, we conducted a moot court simulation exploring the complexities of police conduct, judgment, and constitutional rights. The simulation revolved around a deeply significant case that raises urgent questions about police use of force, the responsibilities of law enforcement, and the constitutional protections afforded to citizens during arrest and detainment. At the heart of this case is a single encounter, a dispute over judgment and force: this is the story of Barnes v. Felix.

The case began on April 28, 2016, when Officer Roberto Felix Jr. of Harris County, Texas, pulled over 24-year-old Ashtian Barnes for toll violations associated with the rental car he was driving. During the stop, Barnes was unable to provide a driver's license or proof of insurance and mentioned that the documents might be in the trunk. Officer Felix claimed to smell marijuana—though none was found—and ordered Barnes to exit the vehicle. As the car began to roll forward with the door open, Felix jumped onto the moving vehicle, pointed his gun at Barnes, and fired two shots, killing him. The entire encounter lasted approximately three minutes.

Barnes's mother filed a lawsuit against Officer Felix, alleging that his use of deadly force violated Barnes's Fourth Amendment rights, which protect against unreasonable searches and seizures. The district court and the U.S. Court of Appeals for the Fifth Circuit dismissed her case under the "moment-of-threat" doctrine, focusing solely on the two seconds after Felix had jumped onto the moving vehicle—at which point he claimed his life was in danger. The courts determined that, in those two seconds, Felix's use of deadly force was justified, and they did not consider the events leading up to that moment.

The Supreme Court is now considering whether courts should apply the "moment-of-threat" doctrine when evaluating an excessive force claim under the Fourth Amendment rather than the “totality of the circumstances” doctrine, which several other circuit courts abide by. This case has significant implications for how courts assess police use of force and the extent to which officers can be held accountable for their actions leading up to a perceived threat.

Unlike the definitive outcome of Citizens United v. FEC, the future of Barnes v. Felix remains uncertain. But its implications are no less significant. As the courts grapple with the facts and constitutional questions, the case reminds us that the interpretation of the law is often as contested as the events that bring such cases to the courtroom.

Feel free to leave your thoughts, opinions, and questions below! If you want to see more cases similar to this one, like this post to let me know!

Sources:

• https://www.oyez.org/cases/2024/23-1239

• https://www.theusconstitution.org/litigation/barnes-v-felix/

• https://www.justice.gov/d9/2025-02/12-1239_barnes.pdf

• https://www.ca5.uscourts.gov/opinions/pub/22/22-20519-CR0.pdf