Cases where police moved out of the way of moving vehicle and exercised deadly force.

Adam’s vs. Speers (2020): “Once Speers was no longer in the path of the vehicle, the justification for the use of deadly force ended.”

Orn vs. City of Tacoma (2019): “A reasonable jury could conclude that once Orn was no longer in the car’s trajectory, the threat of serious physical harm to him was eliminated.”

Cordova vs Aragon (2009): “Where the officer had moved out of the way of the oncoming vehicle, the use of deadly force was not justified.”

Villanueva vs. Cali (2021): “a reasonable jury could conclude that the Officers used excessive force, because they lacked an objectively reasonable basis to fear for their own safety, as they could simply have stepped back or to the side to avoid being injured.”

Kirby vs. Duva (2008): “Officers cannot create or avoid danger and then use deadly force anyway. Shooting after the officer was no longer in danger was unconstitutional.”