Iwoinakee Gebray Harris-Billups v. Milele Anderson, 61 F.4th 1298

On Aug. 2, 2017, Quintas Deshun Harris, suffering psychosis, confronted officers in a DeKalb County apartment complex and twice produced firearms, at one point holding a gun to Officer Milele Anderson’s head.
After a standoff, Harris fired on officers; the group returned fire with 57 bullets that struck Harris four times and left him prone on the pavement; two guns lay nearby.
At the 1:25–1:26 mark of Anderson’s bodycam video, Harris made a sudden, violent lurch; Anderson fired one more round (the 58th), which killed him.
Harris’s mother (as estate administrator) sued under 42 U.S.C. § 1983 for excessive force and added Georgia assault/battery and wrongful-death claims.
The district court granted summary judgment for Officer Anderson on qualified immunity (finding the final shot objectively reasonable) and declined supplemental jurisdiction over state claims; the estate appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourth Amendment excessive-force: was the fatal shot an unreasonable seizure?	The final shot was unnecessary; Harris was wounded, unarmed on the ground, and the lurch was non-threatening.	The split-second lurch could reasonably be perceived as renewal of deadly threat given prior conduct and nearby guns.	Court held the shot was objectively reasonable; no Fourth Amendment violation.
Qualified immunity: is Anderson entitled to immunity from §1983?	Anderson’s conduct violated clearly established rights.	Qualified immunity applies because no constitutional violation.	Court resolved at first prong: no constitutional violation, so qualified immunity applies.
Supplemental jurisdiction: did the district court properly decline to hear state-law claims after dismissing the federal claim?	Plaintiff urged the state claims proceed in federal court.	District court declined under 28 U.S.C. §1367(c)(3) after dismissing federal claim.	Court affirmed district court’s discretionary dismissal of state claims.

Tennessee v. Garner, 471 U.S. 1 (1985) (deadly force constitutes a Fourth Amendment seizure)
Graham v. Connor, 490 U.S. 386 (1989) (excessive-force analysis is an objective-reasonableness inquiry)
Scott v. Harris, 550 U.S. 372 (2007) (video evidence can inform reasonableness analysis)
District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (probable cause is not a high bar)
Mullenix v. Luna, 577 U.S. 7 (2015) (recognizes split-second decisions and deference in use-of-force context)
Montoute v. Carr, 114 F.3d 181 (11th Cir. 1997) (officers need not wait until suspect has aimed before using deadly force)
Long v. Slaton, 508 F.3d 576 (11th Cir. 2007) (suspect’s unstable mental state can support use of deadly force)
Powell v. Snook, 25 F.4th 912 (11th Cir. 2022) (qualified-immunity two-step framework)
Black v. Wigington, 811 F.3d 1259 (11th Cir. 2016) (defines probable cause standard for use of force)
Davis v. Waller, 44 F.4th 1305 (11th Cir. 2022) (reasonableness where suspect is armed; other officers’ inaction not dispositive)
Hunter v. City of Leeds, 941 F.3d 1265 (11th Cir. 2019) (distinguishes cases where additional shots at a surrendered, unarmed suspect were unreasonable)