Mullenix v. Luna

Israel Leija, Jr. (plaintiff) fled from police in a high-speed car chase. Leija called the police during the chase and threatened to shoot officers if they did not abandon their pursuit. Trooper Chadrin Mullenix (defendant) was at an overpass. A spike strip was set up under the pass, and Mullenix had orders to set up a spike strip on the overpass road. However, Mullenix decided to shoot at Leija’s car to disable it. Mullenix learned that an officer was manning the spike strip in the underpass, who could be at risk if Leija shot as he approached the underpass. Mullenix saw Leija’s vehicle come into sight below him. Mullenix shot at Leija’s car six times, striking Leija in the chest four times and killing him. On behalf of Leija and his children, Beatrice Luna and others (plaintiffs) sued Mullenix under 42 U.S.C. § 1983, claiming that Mullenix had used excessive force in violation of Leija’s Fourth Amendment rights. Mullenix moved to dismiss the case, arguing that he was protected by the doctrine of qualified immunity. The district court denied the motion, finding there were factual questions about the reasonableness of Mullenix’s actions that needed to be resolved before the court could rule on the qualified-immunity defense. Mullenix appealed. The United States Court of Appeals for the Fifth Circuit held that Mullenix was not entitled to qualified immunity. The Fifth Circuit found that Mullenix’s actions were objectively unreasonable because he violated the fleeing-felon rule, which was a common-law rule that an officer may not use deadly force against a fleeing felon who does not pose a threat to officers or others. The United States Supreme Court granted certiorari.