McLenagan v. Karnes’s Empirical Analysis
27 F.3d 1002 · 1994
Citation profile
37 federal appellate · 7 district · 2 state decisions
How this case has been cited
Cited by 84 later decisions — most recently February 2025 · most notably Henry v. Purnell (2011), Lowery v. Stovall (1996)
37 federal appellate · 7 district · 2 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Harlow v. Fitzgerald · Board of Regents of State Colleges v. Roth · Anderson v. Creighton · Mitchell v. Forsyth · Joshua Deshaney, a Minor, by His Guardian Ad Litem, and Melody Deshaney,s v. Winnebago County Department of Social Services, et al.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 84 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“For all [the officer] knew, the hesitation involved in giving a warning could readily cause such a warning to be his last. We decline, therefore, to fashion an inflexible rule that, in order to avoid civil liability, an officer must always warn his suspect before firing — particularly where, as here, such a warning might easily have cost the officer his life. ... It is true that [the officer] did not see a gun in [the suspect’s] hands, but it is also true that he could not confirm that [the suspect] was unarmed. We will not second-guess the split-second judgment of a trained police officer merely because that judgment turns out to be mistaken, particularly where inaction could have resulted in death or serious injury to the officer and others. Although it is extremely unfortunate that [the suspect] was seriously injured, § 1983 does not purport to redress injuries resulting from reasonable mistakes. ... [I]n this case, [the officer] had no time to consider anything at all — except his and the public’s immediate safety. At the moment of truth, [the officer] acted well within the range of behavior expected of a police officer. What happened after the critical time had passed is simply irrelevant.”
3 later decisions quote this exact passage · from the majoritye.g. Carr v. Tatangelo · Mack v. Reddick“a police officer’s use of deadly force is not excessive where he has probable cause to believe a suspect poses a threat of serious physical harm to the officers or others,” and that”
1 later decision quote this exact passage · from the majority“[W]e do not think it wise to require a police officer, in all instances, to actually detect the presence of an object in a suspect's hands before firing on him.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.