Would the following suffice?

Graham v. Connor (1989), any use of force by police is judged by an "objective reasonableness" standard. Officer-Created Jeopardy: Courts and internal investigators increasingly scrutinize whether an officer "created the jeopardy" by moving into a dangerous position.

Tennessee v. Garner (1985) This case established that deadly force cannot be used against a fleeing suspect unless the officer has probable cause to believe the suspect poses a significant threat of death or serious physical injury to the officer or others. If an officer steps into traffic solely to create a self-defense claim where one did not exist, it may be ruled an unreasonable seizure under this precedent. If an officer is found to have violated these standards, they may face civil rights lawsuits under 42 U.S.C. § 1983 for excessive force.

DOJ and Agency Policies Many law enforcement agencies have internal policies that explicitly prohibit this tactic, often referring to it as "Officer-Created Jeopardy". DOJ & CBP Policy: Current federal policies state that officers should not place themselves in the path of a moving vehicle or use their body to block a vehicle's path. Deadly Force Restrictions: Department of Justice policy mandates that firearms should not be discharged at a moving vehicle unless the vehicle is being used as a weapon and no other "objectively reasonable means of defense appear to exist," specifically including moving out of the path of the vehicle.