The State-Created-Need Theory: Where Constitutional Reasonableness Meets Progressive Fairness in the Analysis of Excessive Force Claims

Shayna Frieden

On March 13, 2020, just after midnight, three plain-clothed officers broke down Breonna Taylor’s door with a battering ram to execute a search warrant. Breonna Taylor was in bed with her boyfriend, Kenneth Walker. Believing someone had broken in, Walker fired one shot from his licensed handgun, hitting an officer in the leg. The three officers immediately discharged thirty-two rounds, killing Breonna Taylor with six of those shots.

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