Plumhoff v. Rickard: The Supreme Court’s Message to Police on Deadly Force
The Supreme Court’s decision in Plumhoff v. Rickard clarified when officers may lawfully use deadly force to stop dangerous vehicle pursuits. This case continues to guide law enforcement on the balance between protecting public safety and respecting constitutional limits under the Fourth Amendment.
11/6/20251 min read
In Plumhoff v. Rickard (2014), the United States Supreme Court delivered a landmark decision that continues to shape how law enforcement officers apply deadly force in high-speed pursuits. The unanimous ruling sent a clear message to police: when a fleeing suspect poses a grave threat to public safety, officers are legally justified in using deadly force to end that threat.
The case began after a West Memphis, Arkansas officer attempted to stop Donald Rickard for a broken headlight. Rickard fled the scene, leading police on a dangerous chase exceeding 100 miles per hour and crossing state lines. When his vehicle spun out and momentarily stopped, officers approached, but Rickard attempted to flee again—nearly striking another officer in the process. In response, officers fired fifteen shots, ultimately ending the pursuit. Rickard and his passenger were both killed.
The Court, in an opinion authored by Justice Samuel Alito, held that the officers’ actions did not violate the Fourth Amendment. The justices reasoned that Rickard’s conduct posed a “grave public-safety risk,” and that the officers acted reasonably in using deadly force to terminate the chase. The Court emphasized that officers are not required to cease firing until the threat has ended, recognizing the split-second judgments officers must make under extreme pressure.
Furthermore, the Court held that even if a constitutional violation had occurred, the officers would still be entitled to qualified immunity, as their actions did not breach clearly established law at the time. By reaffirming the principles from Graham v. Connor and Scott v. Harris, Plumhoff v. Rickard reinforced that force must be evaluated under an “objective reasonableness” standard—based on what a reasonable officer would perceive on the scene, not through hindsight.
For today’s officers, the Plumhoff decision underscores the importance of articulating the facts and perceived threats in any use-of-force report. The case also highlights the evolving nature of constitutional analysis, especially as courts increasingly weigh “necessary” and “proportional” force in addition to the traditional Graham factors.
Ultimately, Plumhoff v. Rickard stands as a critical reminder: the justification for deadly force hinges on the totality of the circumstances and the immediacy of the threat—not on the number of shots fired or the outcome of the encounter. For law enforcement professionals, understanding this case is essential to staying tactically sound and legally protected in the field.
