Baker v. City of Trenton, No. 18-2181 (6th Cir. 2019)
Annotate this CaseShortly before his high school graduation, 18-year-old Kyle apparently experimented with LSD. The after-effects afflicted him for several days, resulting in his having to be removed from class because of behavioral issues. Kyle’s friend, Collin, checked in on him after school, then went to the police and told them that Kyle needed help and that Kyle was armed and upset with his mother. Four officers went to the house, not knowing that the mother was not actually home with Kyle. Without waiting for a warrant, the officers entered Kyle’s home. He appeared at the foot of the basement stairs, wielding a lawnmower blade. When the officers attempted to subdue Kyle with a taser, he came up the basement stairs swinging. The lawnmower blade struck an officer, who fell back, then shot and killed Kyle. The Sixth Circuit affirmed summary judgment in favor of the defendants in a suit under 42 U.S.C. 1983. Calling the case “heart-rending, the court stated that given the circumstances and governing case law, the officers’ entry into Kyle’s home was justified under the exigent-circumstances exception and the use of force did not violate the Fourth Amendment. The officer had probable cause to believe that Kyle posed a significant threat of death or serious physical injury.
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