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11 Am. J. Police 97 (1992)
Forces of Change in Police Policy: The Impact of Tennessee v. Garner

handle is hein.journals/ajpol11 and id is 301 raw text is: American Journal of Police Vol. XI, No. 3 1992

FORCES OF CHANGE IN POLICE POLICY:
THE IMPACT OF TENNESSEE v. GARNER
Samuel Walker
University of Nebraska at Omaha
Lorie Fridell
Florida State University
In 1985, the U.S. Supreme Court handed down the decision in
Tennessee v. Garner (471 U.S. 1), which restricts the circumstances
under which law enforcement officers may use deadly force to arrest.
Following the announcement of this decision, newspapers and news
magazines proclaimed that the Supreme Court had struck down ap-
proximately 21 state statutes-implying that this decision would have a
major impact on deadly force policy nationwide. Although the infor-
mation regarding the statutes was true, the implication that this deci-
sion would force major changes in law enforcement policy was not.
This article explores the change process relative to deadly force
law and policy, culminating in the U.S. Supreme Court decision on this
topic. We include data from a survey of police departments in major
U.S. cities regarding the impact of Tennessee v. Garner on their poli-
cies. The survey results and the historical analysis of the change pro-
cess are discussed in terms of future developments in police policy and
the role of the U.S. Supreme Court in those developments.
THE GARNER DECISION
The Garner case involved the death at police hands of a fifteen-
year-old male who had broken into an unoccupied house and stolen a
ring and a coin purse containing ten dollars. Memphis police were on

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