Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-29

The Fourth Circuit affirmed the district court’s grant of summary judgment in favor of the City of Charlotte and three law enforcement officers on claims alleging excessive force under the Fourth Amendment and failure to accommodate a disability under the Americans with Disabilities Act (ADA). The court held that the officers’ use of deadly force was objectively reasonable because, from the perspective of an officer on the scene, Bobby Morgan posed an imminent threat of serious physical harm by repeatedly drawing and discharging a firearm in a residential neighborhood while defying commands to stand down. The court applied the totality-of-the-circumstances test under *Graham v. Connor*, emphasizing that the suspect’s gun appeared functional and sounded like a real weapon, rendering the officers’ belief that it could fire lethal bullets reasonable even though it was actually a prop gun firing only blanks. Additionally, the court rejected the argument that the officers failed to deescalate or accommodate Morgan’s mental illness, ruling that exigent circumstances arising from active gunfire justified the use of force and that the ADA requires reasonableness rather than perfection, particularly when time is of the essence. Consequently, the City of Charlotte bears no liability for the officers’ actions, and the judgment in favor of the defendants remains in effect.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.