What is the test for a police officer to shoot and kill a suspect who is not facing the police?

MultiRegion, United States of America

The following excerpt is from Bray v. County of San Diego, 19 F.3d 26 (9th Cir. 1994):

Our decision is consistent with Curnow v. Ridgecrest Police, 952 F.2d 321 (9th Cir.1991). In Curnow, we held that it was unreasonable for a police officer to shoot at a suspect who was reaching for, but not pointing, a semi-automatic rifle and who was not facing the police. If a reasonable officer should not have used deadly force in Curnow, where there was a firearm in plain view, then a reasonable officer certainly should not have done so here.

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