Unanimous US Supreme Court ruling could change police force cases nationwide
While lower courts have been split in how they analyze officer use of force in fatal shootings, a 2016 traffic stop has now prompted the Supreme Court to rule
(InvestigateTV) — Traffic stops are among the most unpredictable and potentially dangerous encounters for both law enforcement and civilians.
The uncertainty of who is being approached and how a situation might escalate could influence an officer’s split-second judgment during life-and-death situations, experts said.
According to the non-profit advocacy group Mapping Police Violence, more than 1,200 people were killed by police in 2024, and 12% of those deaths involved people stopped for alleged traffic violations.
While the country’s lower courts have been split in how they analyze officer use of force in fatal shootings, a 2016 traffic stop has now prompted the Supreme Court to weigh in. The decision reshapes precedent for the country and gives one mother a long-awaited step toward justice.
The Fatal Encounter
On the side of a toll road near Houston in 2016, a police encounter escalated quickly. For mother Janice Hughes, the dash cam video is difficult to watch.
“I just can’t. I think I may have watched it twice,” Hughes said.
According to legal documents, Officer Roberto Felix Jr. pulled over Hughes’ son, 24-year-old Ashtian Barnes, after his rental car was flagged for unpaid tolls.
“By all accounts, yes ma’am. He didn’t have to be dead,” Hughes said when asked if it should have been a routine traffic stop.
In the video, Barnes tells Officer Felix he doesn’t have identification on him. Rather than exiting the vehicle when instructed, he started to drive away, and Officer Felix jumped onto the car’s door sill.
The officer fired twice, fatally wounding Barnes, who died at the scene.
Following the deadly shooting, an internal investigation by Harris County’s Constable Office found Officer Felix didn’t violate procedure, and a review by the Houston Police Department said the “shooting appears to be justified.” No criminal charges were filed.
The Legal Battle
“It still brings tears to my eyes when I think about it,” Hughes said. “He was a joy. Just an all-around loving guy.”
In 2017, she filed a lawsuit alleging Officer Felix used excessive force that violated her son’s constitutional rights.
“He didn’t do nothing. He didn’t do nothing,” Hughes said.
The case worked its way through federal court, eventually making it to the United States 5th Circuit Court of Appeals.
In 2024, the 5th Circuit upheld a lower court’s ruling that Officer Felix’s actions were justified given the immediate threat he faced at the time of the shooting.
The decision was based on a legal doctrine known as “the moment of threat.”
The doctrine focuses on whether the time during the traffic stop, before Officer Felix was on the moving car, factors into the court’s decision on whether his use of deadly force was justified.
“The fact that he jumped onto the car and put himself into danger is the issue here,” said Hughes’ attorney Adam Fomby.
Fomby argues that what happened before Officer Felix was on the door sill of the car is relevant.
“Judge Higginbotham from the Fifth Circuit even said, if he had looked at the totality of the circumstances, he would have found the officer was at fault for this incident,” Fomby said.
There are 12 regional courts of appeals in the federal system. In deadly force cases, eight of them have considered an officer’s actions leading up to the use of force when issuing their rulings. But the other four, including the 5th Circuit, would apply “the moment of threat” standard, which focuses solely on the instant the officer used force.
Georgetown Law Professor Christy Lopez said she believes some circuits have used the moment of threat doctrine to protect law enforcement.
“It was really a way, in my view, to ensure that courts weren’t being too hard on officers who get into these difficult, tumultuous situations and find themselves having to use force,” Lopez said.
Supreme Court intervention
These differing opinions created a legal split.
In an effort to establish a uniform standard nationwide, the Supreme Court stepped in, hearing arguments in January 2025 in Barnes v. Felix.
In May 2025, the Supreme Court unanimously rejected the ‘moment of threat" doctrine, meaning lower courts must now consider the time leading up to an officer’s use of deadly force when deciding if it was reasonable.
“Every single officer that’s trained is going to know how the Supreme Court found on this case. It’s going to affect how they interact with everyday people on the streets,” Fomby said.
Lopez said it’s a step toward greater accountability for law enforcement.
“What we find is that when we hold officers accountable for the force that they use, it often results in better training and better policies that keep officers safer as well as members of the public safer,” Lopez said.
Law enforcement perspective
Some in the policing community caution against questioning an officer’s split-second decision.
“Accountability is not really a problem in law enforcement,” said Kevin Lawrence, executive director of Texas Municipal Police Association and a retired law enforcement officer.
“You should look at the totality of the circumstances, but you should not go back and say wait a minute, this violation of policy or this tactical error somehow contributed to the danger and therefore it does excuse the behavior of the suspect.”
Lawrence said he understands how an officer could fear for their life in a situation like Felix encountered.
“If I let that guy keep going and get up to 75, 80 miles an hour of me hanging on the side of the car, there is no doubt my life is in danger,” Lawrence said.
“Yes. I think it’s a reasonable use of force. Anytime that you believe that your life is in danger, you are justified in the use of deadly force.”
Unresolved questions
While they made their decision about the “moment of threat” doctrine, the Supreme Court chose not to rule on whether Officer Felix created the danger that ultimately led to Barnes’ death. The justices left that question for the lower courts to decide.
“They went with this very narrow opinion that did not say anything about whether and how courts should consider officer-created jeopardy,” Lopez said.
During the proceedings, Justice Brett Kavanaugh reminded courts that law enforcement doesn’t have the benefit of hindsight.
“An officer does not get the time we’ve spent here today to make the decision,” Kavanaugh said during Supreme Court arguments.
“It’s been a tough journey,” Hughes said. “Patience is what I have learned.”
Hughes said she’s grateful that patience has finally paid off, finding comfort in the bittersweet legacy her son leaves behind and knowing he would be proud.
“I think he would say, Mom, you did it all, and that’s the ultimate result there. I love you forever, baby. And this is never gonna be over,” Hughes said.
The Supreme Court’s ruling sets a precedent that could have a significant impact on police use of force cases moving forward, but it didn’t mark the end of Barnes v. Felix. The justices sent the case back to the lower courts, asking them to consider the reasonableness of the shooting using the lengthier timeframe they prescribed.
Legal representatives for Officer Felix and Harris County declined to speak.
Addressing the Supreme Court in January 2025, Felix’s attorney said he “reasonably believed that his life was in imminent danger. That conclusion should end this case.”
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