Betty Jo Shelby v. Michael Manning, as Administrator of the Estate of Terence Crutcher, Sr., et al.

This Court has repeatedly reversed lower courts for denying qualified immunity based on generalized excessive force principles rather than precedent addressing the officer’s specific conduct under the particular circumstances confronted. See, e.g., Brosseau, Mullenix, White, Kisela, Bond, and Rivas-Villegas. Most recently, in Zorn v. Linton, this Court summarily reversed the Second Circuit for denying qualified immunity based on generalized excessive force principles rather than precedent addressing the officer’s specific conduct with a “high degree of specificity.” 146 S. Ct. 926, 930 (2026). The decision below reflects the same error this Court corrected in Zorn. Officer Betty Shelby encountered an individual she reasonably believed was impaired or experiencing a mental-health crisis who had abandoned a running vehicle in the middle of a roadway and then moved back toward that vehicle, creating uncertainty regarding his intentions and the circumstances confronting the officer. App. B at 27a-29a. The district court nevertheless concluded Respondent failed to identify precedent squarely governing Officer Shelby’s conduct under those circumstances. App. B at 37a-40a. The Tenth Circuit reversed, relying on generalized principles derived from Garner because the decedent was allegedly “unarmed” and “nondangerous.” App. A at 14a-15a. The question presented is: Whether the Tenth Circuit’s qualified immunity analysis conflicts with this Court’s repeated instruction that clearly established law must