Barnes v. Felix (2025) might apply here

[Kaleva]

“Conclusion

The holding in this case will have a significant effect on municipalities and their police departments and officers. In this ruling, the Supreme Court reiterated that courts must evaluate the totality of the circumstances known to officers before and during an event that requires the use of deadly force. This decision is important because it supports and encourages officers to evaluate all circumstances that they are aware of when determining whether to use force. This increases the likelihood that force will only be employed when necessary to protect them from legitimate threats of danger.“

https://www.ktjlaw.com/blog/in-barnes-v-felix-145-s-ct-1353-2025-the-united-states-supreme-court-holds-that-the-moment-of-threat-rule-is-unconstitutional-in-evaluating-excessive-force-claims/

The ICE agent put himself in front of the vehicle. None of the other agents drew their guns when approaching the car. The Supreme Court decision requires that law enforcement consider the totality of the situation before using deadly force.

[Kaleva]

1. Some more info

“The Department of Justice says in its Justice Manual that firearms should not be used simply to disable a moving vehicle. The policy allows deadly force only in limited circumstances, such as when someone in the vehicle is threatening another person with deadly force, or when the vehicle itself is being used in a way that poses an imminent risk and no reasonable alternative exists, including moving out of the vehicle’s path.“

https://www.clickorlando.com/news/politics/2026/01/08/fatal-shooting-by-ice-agent-in-minneapolis-raises-questions-about-officers-firing-at-moving-vehicles/


Videos show that the ICE agent was able to get out of the vehicles path but he still shot anyways.

[unblock]

3. Exactly. It did nothing to increase his own safety if he even was in danger.

The last thing a car with an incapacitated driver is going to do is immediately stop.

[unblock]

2. It's even simpler in this case.

Whatever reasons he may have has for shooting her, defense was not among them.

Shooting the driver of a car heading toward you does nothing to increase your own safety. If the driver is incapacitated, the car is not going to abruptly stop. It's far more likely to simply continue in a straight line (as actually happened) which is the last thing you want if you're trying to defend yourself.

It's literally not an act of defense. It didn't increase his own safety in any way.

Never mind that he was able to just casually walk out of the way. It's not like he had to do an acrobatic leap and roll. It's just plain ludicrous to even pretend this was an act of self-defense.


But yes, the case you cite may be helpful in allowing the jury to consider all the other motives he may have had to shoot.