On May 15, 2025, the United States Supreme Court issued Barnes v. Felix, a use of force case. On April 18, 2016, officer Felix fatally shot Barnes following a lawful traffic stop. Whether use of force by police officers is excessive leading to a potential Section 1983 civil rights violation lawsuit against the officer and his department is treated differently in the U.S. depending on where the incident occurred. The United States Supreme Court has specified that courts are to look to the totality of the circumstances when determining whether force is excessive or not. And lethal force may be employed when the officer has probable cause to believe that the suspect poses a threat to the officer or someone else. For a time, the federal appellate courts differed on use of deadly force with some courts analyzing the situation at the moment of threat (mere seconds prior to firing a weapon at a suspect) and other federal circuits looking at the events leading up to the use of deadly force including immediately prior to its use. In Barnes v. Feliz the Supreme Court resolved the circuit split holding that the totality of the circumstances is the proper test. The Court stated that while the precise time of the shooting is often what matters most, courts must look to all relevant matters coming before.