In Deorle v. Rutherford, 272 F.3d 1272 (9th Cir. 2001), the Court held that shooting a beanbag projectile at a suicidal, irrational individual who was walking directly towards an officer was excessive, given that the crime he committed was minor, the danger to the officer and others was minimal, there was no immediate need to subdue him, and he was not given any warning that he would be shot if he continued to approach the officer. 272 F.3d at 1282. The Court also denied qualified immunity, concluding that every police officer should have known that it was objectively unreasonable to use such force under those circumstances. Id. at 1285.