to the already serious crime of burglary. The Tennessee statute represents the state legislature's judgment that such crimes may require the use of deadly force in order to protect the public against those who commit such crimes. She also disagreed that a suspect's interest in his own life necessarily allows the right to flee from the scene of a crime when pursued, thereby escaping due process, although the majority did not find nor articulate any "right to flee". Limitations of impact Garner brought his suit under 42 U.S.C. § 1983, which extends to citizens' protection from violations of their civil rights by "persons", including persons acting in their official capacity as officers of the states. Accordingly, the Court's holding under this Section sets a standard that state police departments must comply with. In practice, however, the Garner case has had less impact on state-level police practices than was originally anticipated. This is because Garner, and a subsequent case, Graham v. Connor, established that the reasonableness of an officer's use of force, whether against a fleeing suspect or otherwise, is to be determined from the perspective of the officer under the circumstances that were apparent to them at the time. As the Graham court made clear, this deferential standard prevents most second-guessing of an officer's judgment about use of force. It may be that Garner's legacy is not so much one of changing the use of deadly force by police as it is of eliding use of force policies and practices by shifting them from the statutory to the customary. Tennenbaum shows a significant reduction (16%) in the number of police homicides committed before, and after the decision. This reduction was more significant in states which declared their laws regarding police use of deadly force to be unconstitutional after the Garner decision. The evidence suggests that the reduction is due not only to a reduction in shooting fleeing felons, but also to a general reduction in police shooting. These empirical findings prove, that despite suspicion about the ability of the Supreme Court to change police discretion, the Garner decision demonstrates that a decision can have a strong effect on police behavior. See also Graham v. Connor (1989) White v. Pauly (2017) List of United States Supreme Court cases, volume 471 Use of force continuum References External links 1985 in United States case law United States Fourth Amendment case law United States