Mullenix v. Luna, 136 S. Ct. 305

Background

Trooper Chadrin Mullenix, without prior training in the tactic and after his supervisor told him to “stand by,” fired six rifle rounds from an overpass at Israel Leija Jr.’s speeding car during an 18‑minute high‑speed chase; four shots struck and killed Leija.
Leija had driven 25 miles at 85–110 mph, was reportedly intoxicated, and twice told dispatch he had a gun and would shoot officers if pursuit continued.
Officers had deployed spike strips at three locations; one set lay directly beneath the overpass where Mullenix positioned himself and Officer Ducheneaux was stationed nearby.
Mullenix testified he intended to disable the car (targeting the engine) to avoid risks posed by spike strips; no evidence showed his shots hit the engine.
Plaintiffs sued under 42 U.S.C. § 1983 for excessive force (Fourth Amendment). The district court and Fifth Circuit denied qualified immunity; the Supreme Court granted review and reversed on qualified immunity grounds.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mullenix is entitled to qualified immunity for shooting at a fleeing car that killed the driver	Mullenix violated clearly established Fourth Amendment law by using deadly force when nonlethal spike strips were in place and his supervisor ordered to wait	Mullenix reasonably perceived an imminent threat to officers (high speed, threats to shoot, proximity to an officer beneath the overpass) and acted within a gray area of law	Court reversed Fifth Circuit: qualified immunity applies because existing precedent did not place the unlawfulness of Mullenix’s conduct "beyond debate"
What degree of specificity is required to find law "clearly established" in excessive‑force, high‑speed chase cases	Plaintiffs: clearly established that deadly force is forbidden absent a sufficient, immediate threat and alternatives should be used	Defendant: precedents are fact‑specific; here facts (threats, speed, proximity to officers) justified perceiving an immediate danger	Court: must evaluate precedent in the specific factual context; prior cases did not ‘‘squarely govern’’ these facts, so the law was not clearly established
Whether choosing to shoot rather than wait for spike strips violated clearly established law	Plaintiffs: shooting before testing spike strips was unreasonable and contradicted supervisory orders; no special governmental interest justified bypassing the spikes	Defendant: spike strips can fail and expose officers; shooting was a reasonable, though risky, alternative to protect officers	Court: lower‑court reliance on spike‑strip alternative did not overcome qualified immunity because no precedent clearly established that choosing one dangerous tactic over another was unlawful in these circumstances

Key Cases Cited

Pearson v. Callahan, 555 U.S. 223 (establishes qualified immunity framework allowing courts to decide necessity of constitutional violation or clearly established law first)
Harlow v. Fitzgerald, 457 U.S. 800 (formulates modern qualified immunity standard)
Ashcroft v. al‑Kidd, 563 U.S. 731 (requires precedent to place constitutional question beyond debate for denial of immunity)
Brosseau v. Haugen, 543 U.S. 194 (emphasizes fact‑specific nature of excessive‑force claims and rejects broad formulations of clearly established law)
Scott v. Harris, 550 U.S. 372 (upholds use of force in dangerous high‑speed chase where suspect’s driving posed an imminent threat)
Saucier v. Katz, 533 U.S. 194 (discusses sequence of qualified immunity analysis and need for context‑specific inquiry)
Tennessee v. Garner, 471 U.S. 1 (frames deadly‑force principles against fleeing felons; treated as general rule not dispositive here)
Anderson v. Creighton, 483 U.S. 635 (requires the specific circumstances confronting officers be considered when assessing clearly established law)
Malley v. Briggs, 475 U.S. 335 (qualified immunity protects all but plainly incompetent or those knowingly violating the law)