Hunter Tillis v. Allan H. Brown, Jr., 12f4th1291

Late-night high-speed chase across state lines ended when Christian Redwine crashed a Pontiac into bushes; Officer Allan H. Brown Jr. parked behind/to the right and exited to arrest the occupants.
Seconds after Brown exited, the Pontiac’s reverse lights came on and it backed straight past him; Brown fired 11 shots through the rear and side windows as it passed (≈3 seconds).
The Pontiac rolled to a stop with engine/headlights running; Brown changed magazines, advanced, and fired another 10 shots at the front (≈3–4 seconds); total shooting occurred in <13 seconds.
Redwine died; two passengers were wounded. Plaintiffs (survivors and Redwine’s administratrix) sued under §1983 and state law against Brown, Chief Boren, and the Consolidated Government of Columbus.
District court granted summary judgment to Brown for the first round but denied it for the second; Eleventh Circuit majority held both rounds objectively reasonable and granted qualified and state-law immunity to Brown, Chief Boren, and the county; Judge Jill Pryor dissented.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonableness of first round of shots	Shooting was unreasonable—driver did not use/threaten vehicle as a weapon; officer was not in vehicle’s path.	Reasonable officer could perceive imminent danger when the car reversed and passed within a few feet.	Affirmed: first round reasonable; no Fourth Amendment violation.
Reasonableness of second round of shots	Continued shooting after car stopped was excessive; no ongoing imminent threat.	Officer entitled to continue until suspect secured; running engine/headlights and recent close pass created ongoing threat.	Reversed district court: second round reasonable; qualified immunity granted.
Qualified / state-law immunity for Brown	Not entitled for second round (and first round challenged on cross-appeal).	Entitled to qualified immunity because use of force was objectively reasonable under precedent.	Brown entitled to qualified immunity and state-law immunity for all claims; judgment rendered for Brown.
Municipal / supervisory liability (Chief Boren, County)	County/chief liable for policies, customs, or failure to supervise permitting excessive force.	Chief not personally involved; county only potentially liable if Brown violated rights.	Summary judgment for Chief affirmed; county judgment rendered for defendants because Brown committed no constitutional violation.

Tennessee v. Garner, 471 U.S. 1 (U.S. 1985) (governs constitutionality of deadly force under Fourth Amendment)
Plumhoff v. Rickard, 572 U.S. 765 (U.S. 2014) (assesses reasonableness of deadly force in high-speed-chase context; officers need not stop firing until threat ends)
Pace v. Capobianco, 283 F.3d 1275 (11th Cir. 2002) (upheld deadly force where fleeing driver used automobile as a weapon)
Singletary v. Vargas, 804 F.3d 1174 (11th Cir. 2015) (use of deadly force reasonable where vehicle accelerated toward officer and officer was in path)
Jean-Baptiste v. Gutierrez, 627 F.3d 816 (11th Cir. 2010) (reasonableness judged from perspective of reasonable officer on scene; split-second judgments)
Mitchell v. Forsyth, 472 U.S. 511 (U.S. 1985) (denial of qualified immunity is immediately appealable as an issue of law)