Source: National Association of Police Organizations.
The Washington Report: The Newsletter of the National Association of Police Organizations
June 6, 2025
Don’t Hesitate! Register Today for NAPO’s 47th Annual Convention
July 20–23, 2025
Arizona Biltmore Resort
Join us for NAPO’s 47th Annual Convention at the Arizona Biltmore Resort in Phoenix. Participate in setting NAPO’s legislative priorities for the 119th Congress. Learn from presentations by prominent law enforcement figures about the latest developments in police policies and services, and help determine NAPO’s path forward by participating in the election of NAPO’s Leadership.
The iconic Arizona Biltmore Resort was built in 1929, is a historic landmark, and is the only Frank Lloyd Wright–influenced resort in the world. The resort offers stunning views of the Phoenix Mountain Preserve and has everything needed for a perfect week:
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7 Spectacular Pools, including Adult Only Pool and Family Pool with 65’ Water Slide
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2 PGA Golf Courses, Tennis, Pickleball Courts, Trails, and Bikes
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Tierra Luna Full-Service Spa
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Many Upscale Restaurants, Lounges, and Pool Bars
Very special thanks to Darrell Kriplean and the Phoenix Law Enforcement Association and all our NAPO member associations from Arizona for sponsoring many of the convention’s events. Without their financial support and tireless efforts, many of the events simply would not have been possible!
For more information and to register, please visit www.napo.org/convention25
Supreme Court Rules on Use of Force in Barnes v. Felix
The U.S. Supreme Court issued a decision on May 15, 2025, in Barnes v. Felix regarding how courts should analyze the use of force by officers. In its decision, the Supreme Court ruled that courts must consider the totality of the circumstances, not just the split second when an officer perceives a threat.
The case involves a routine traffic stop during which Harris County (Texas) Officer Roberto Felix, Jr., pulled over Ashtian Barnes for suspected toll violations. Officer Felix asked Barnes for his driver’s license and a tense exchange occurred, which included Officer Felix telling Barnes to stop “digging” in the car and requesting he open the trunk. When Officer Felix ordered Barnes out of the vehicle, Barnes attempted to drive away with the car door still open. Officer Felix put his foot on the driver’s side doorsill and ordered Barnes to stop moving multiple times. When Barnes failed to comply, Officer Felix did what any reasonable officer would do to safeguard his own life and that of others and took two shots, killing Barnes.
Lower courts ruled that only the final two seconds—when Felix was on the doorsill—mattered, not what led to that moment.
NAPO joined with our member organization, the Combined Law Enforcement Associations of Texas (CLEAT), in an amicus brief affirming the constitutionality of Officer Felix’s actions and calling on the Court to clarify that judges may review segments of an event which precede the use of deadly force only for the purpose of determining the officer’s knowledge, not to second-guess an officer’s prior tactics, actions, or decisions.
Lower courts have been split in how they analyze officer use of force, with some using “the moment of threat,” isolating only the brief instance before deadly force was used, and others using the “totality of the circumstances,” assessing all events leading up to the use of force.
In its ruling in Barnes v. Felix, the Supreme Court ruled that courts must examine the “totality of the circumstances,” the prior actions and decisions of both the officer and the suspect, in determining the reasonableness of force. The Supreme Court did not decide, however, whether an officer’s own actions creating a dangerous situation affect the reasonableness of the force used.
With this ruling, the Fifth Circuit’s judgment in favor of Officer Felix is vacated and the case is now remanded to be reconsidered under the correct “totality of the circumstances” standard.
NAPO will continue to closely follow this case, and others that impact officers’ ability to use force for the protection of themselves and others.
