Editing Deadly force (section)

=== In relation to motor vehicles ===
In {{cite court
  |litigants=Scott v. Harris
  |vol=
  |reporter=
  |opinion=No. 05-1631
  |pinpoint=
  |court=
  |date=April 30, 2007
  |url=https://www.law.cornell.edu/supct/html/05-1631.ZS.html
}}, the [[U.S. Supreme Court]] held that a police officer's attempt to terminate a dangerous high-speed car chase that threatened the lives of innocent bystanders did not violate the [[Fourth Amendment to the United States Constitution|Fourth Amendment]], even when it places the fleeing [[motorist]] at risk of serious bodily injury or death. In the ''Harris'' case, Officer Scott [[PIT maneuver|applied his police car's push bumper to the rear of the suspect's vehicle]], causing the [[suspect]] vehicle to lose control and crash, resulting in the fleeing suspect being paralyzed from the waist down.<ref name="robertankony" />

Traditionally, intentional contact between vehicles has been characterized as unlawful deadly force, though some U.S. federal appellate cases have mitigated this precedent. In
{{cite court
  |litigants=Adams v. St. Lucie County Sheriff's Department
  |vol=998
  |reporter=F.2d
  |opinion=923
  |court=11th Cir.
  |date=1992
  |url=https://www.leagle.com/decision/19922525962f2d156312303
}},
the Eleventh Circuit Court of Appeals ruled that, although fatalities may result from intentional collisions between automobiles, such fatalities are infrequent and therefore unlawful deadly force should not be presumed to be the level of force applied in such incidents; the Adams case was subsequently called into question by
{{cite court
  |litigants=Harris v Coweta County
  |vol=406
  |reporter=F.3d
  |opinion=1307
  |court=11th Cir.
  |date=2005
  |url=https://www.llrmi.com/articles/legal_update/ramming
}}, which in turn was reversed by the U.S. Supreme Court in the ''Scott v. Harris'' case discussed above; the extent to which ''Adams'' can continue to be relied on is uncertain. In the ''Adams'' case, the officer rammed the suspect's vehicle.

In
{{cite court
  |litigants=Donovan v. City of Milwaukee
  |vol=17
  |reporter=F.3d
  |opinion=944
  |court=7th Cir.
  |date=1994
  |url=https://openjurist.org/17/f3d/944/donovan-v-city-of-milwaukee-c
}}, the Seventh Circuit Court of Appeals recognized this principle but added that collisions between automobiles and motorcycles frequently lead to the death of the motorcyclist, and therefore a presumption that unlawful deadly force was used in such intentional collisions is more appropriate. In the ''Donovan'' case, the suspect lost control of his motorcycle and became airborne, crashing into the officer's vehicle, which was parked as part of an intercepting roadblock.