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City of Los Angeles, California, et al. v. Estate of Daniel Hernandez, By and Through Successors in Interest, Manuel Hernandez, Maria Hernandez, and M. L. H., et al.

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 21-55994, 21-55995 · judgment June 2, 2025


Certiorari denied · June 22, 2026
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

This case arises from a split-second police encounter in which an officer fired six shots in six seconds at a suspect armed with a knife who appeared to be regaining his footing to continue his advance. The Ninth Circuit, relying on slow-motion parsing of body-camera footage, deemed the first four shots constitutionally reasonable but held the last two – fired no more than one second thereafter – to constitute excessive force, despite this Court’s repeated admonitions against such artificial segmentation of fastmoving events. In doing so, the Ninth Circuit not only fractured established Fourth Amendment precedent, but also expanded its own “moment-of-threat” jurisprudence in direct conflict with this Court’s recent and unanimous rejection of that approach. Petitioners respectfully submit the following questions presented:

  1. Whether the Ninth Circuit disregarded this Court’s precedents, including Graham v. Connor, 490 U.S. 386 (1989), and Plumhoff v. Rickard, 572 U.S. 765 (2014), by artificially parsing a six-second event into discrete segments, finding the first four shots reasonable, but the final two unconstitutional based on a split-second gap and slow-motion video review. An approach that also conflicts with other circuits considering similar facts.

  2. Whether the Ninth Circuit effectively adopted a new and more extreme “moment-of-threat” rule that this Court unanimously rejected in Barnes v. Felix, 605 U.S. 73, 145 S. Ct. 1353 (2025).

Counsel of record

For petitioner
Kevin E. Gilbert
Orbach Huff + Henderson

For respondent
Erwin Chemerinsky

Case

Conference history
Distributed for 13 conferences

Amicus briefs
1 cert-stage

Linked docket
25A167

Proceedings

  1. Jun 22 2026
    Petition DENIED. Justice Thomas and Justice Alito would grant the petition for a writ of certiorari.
  2. Jun 15 2026
    DISTRIBUTED for Conference of 6/18/2026.
  3. Jun 08 2026
    DISTRIBUTED for Conference of 6/11/2026.
  4. Jun 01 2026
    DISTRIBUTED for Conference of 6/4/2026.
  5. May 26 2026
    DISTRIBUTED for Conference of 5/28/2026.
  6. May 18 2026
    DISTRIBUTED for Conference of 5/21/2026.
  7. May 11 2026
    DISTRIBUTED for Conference of 5/14/2026.
  8. Apr 27 2026
    DISTRIBUTED for Conference of 5/1/2026.
  9. Apr 20 2026
    DISTRIBUTED for Conference of 4/24/2026.
  10. Apr 13 2026
    DISTRIBUTED for Conference of 4/17/2026.
  11. Mar 30 2026
    DISTRIBUTED for Conference of 4/2/2026.
  12. Mar 23 2026
    DISTRIBUTED for Conference of 3/27/2026.
  13. Feb 25 2026
    DISTRIBUTED for Conference of 3/20/2026.
  14. Feb 05 2026
    Brief of respondents Estate of Daniel Hernandez, et al. in opposition filed.
  15. Dec 17 2025
    Motion to extend the time to file a response is granted and the time is extended to and including February 9, 2026.
  16. Dec 16 2025
    Motion to extend the time to file a response from January 8, 2026 to February 9, 2026, submitted to The Clerk.
  17. Dec 09 2025
    Response Requested. (Due January 8, 2026)
  18. Dec 03 2025
    DISTRIBUTED for Conference of 1/9/2026.
  19. Dec 03 2025
    Brief amicus curiae of National Police Association filed.
  20. Dec 01 2025
    Waiver of right of respondent Estate of Daniel Hernandez, et al. to respond filed.
  21. Oct 30 2025
    Petition for a writ of certiorari filed. (Response due December 3, 2025)
  22. Aug 11 2025
    Application (25A167) granted by Justice Kagan extending the time to file until October 30, 2025.
  23. Aug 05 2025
    Application (25A167) to extend the time to file a petition for a writ of certiorari from August 31, 2025 to October 30, 2025, submitted to Justice Kagan.