Schulz v. Long – Case Brief Summary (Federal Court)

In Schulz v. Long, 44 F.3d 643 (8th Cir. 1995), the parents of the appellant, a paranoid schizophrenic, called the police to help them with the appellant's aberrant behavior. Id. at 645.

When the police arrived at the home, the appellant was in the basement, where he had erected a barricade. Id.

Two officers stood at the landing at the bottom of the basement stairwell and attempted to convince the appellant to go to the hospital. Id. at 645-46.

At some point, the appellant obtained a double-bladed axe and approached one officer in a threatening manner. Id. at 646.

The other officer ordered the appellant to drop the axe and, when the appellant did not comply, the officer shot him. Id.

The appellant brought a federal civil rights action against the officers involved in the incident. Id. at 645. The court granted judgment as a matter of law as to one defendant, and a jury found in favor of the remaining defendants. Id.

On appeal, appellant challenged the exclusion of evidence relating to the officers' actions leading up to the shooting. Id.

In response to the appellant's argument that the officers should have used a lesser degree of force, the Schultz court stated:

The Fourth Amendment does not allow this type of "Monday morning quarterback" approach because it only requires that the seizure fall within a range of objective reasonableness . . . . It could be argued, of course, that the officer's decision to use deadly force might not have been the most prudent course of action; other courses of action . . . might conceivably have been available. The Constitution, however, requires only that the seizure be objectively reasonable, not that the officer pursue the most prudent course of conduct as judged by 20/20 hindsight vision.

The Fourth Amendment inquiry focuses not on what the most prudent course of action may have been or whether there were other alternatives available, but instead whether the seizure actually effectuated falls within a range of conduct which is objectively "reasonable" under the Fourth Amendment. Alternative measures which 20/20 hindsight reveal to be less intrusive (or more prudent), such as waiting for a supervisor or the SWAT team, are simply not relevant to the reasonableness inquiry. Id. at 649.