Brittany Ruffin v. Kevin Davis

── Brittany Ruffin v. Kevin Davis ── Court: Court of Appeals for the Fourth Circuit Date: April 29, 2026 Category: General USCA4 Appeal: 25-1318 Doc: 46 Filed: 04/29/2026 Pg: 1 of 12 PUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25-1318 BRITTANY RUFFIN, individually, and as Personal Representative for the Estate of J.R., Plaintiff – Appellee, v. KEVIN DAVIS, Defendant – Appellant, and WILLIAM HOLBROOK, individually; CITY OF COLUMBIA POLICE DEPARTMENT; CITY OF COLUMBIA, Defendants. Appeal from the United States District Court for the District of South Carolina, at Columbia. Sherri A. Lydon, District Judge. (3:23−cv−01425−SAL) Argued: January 28, 2026 Decided: April 29, 2026 Before DIAZ, Chief Judge, and THACKER and BERNER, Circuit Judges. Affirmed by published opinion. Chief Judge Diaz wrote the opinion, in which Judge Thacker and Judge Berner joined. USCA4 Appeal: 25-1318 Doc: 46 Filed: 04/29/2026 Pg: 2 of 12 ARGUED: John S. Nichols, BLUESTEIN THOMPSON SULLIVAN, LLC, Columbia, South Carolina, for Appellant. Mary H. Schnoor, MCDERMOTT WILL & SCHULTE, Washington, D.C., for Appellee. ON BRIEF: Mary Daniel LaFave, LAFAVE BAGLEY, LLC, Columbia, South Carolina, for Appellant. Justin T. Bamberg, Adam C. Ness, BAMBERG LEGAL, LLC, Bamberg, South Carolina; Paul W. Hughes, MCDERMOTT WILL & SCHULTE LLP, Washington, D.C., for Appellee. 2 USCA4 Appeal: 25-1318 Doc: 46 Filed: 04/29/2026 Pg: 3 of 12 DIAZ, Chief Judge: This case arises from the fatal police shooting of a teenager. Officer Kevin Davis was patrolling a neighborhood under curfew due to the COVID-19 pandemic when he encountered J.R., a high school senior, on the sidewalk. As Davis approached, J.R. took off running. Davis followed. The chase turned deadly when J.R. ignored several commands and Davis noticed that he was armed. Davis fired his weapon at J.R. multiple times, ultimately hitting him in the forehead and killing him. Plaintiff, J.R.’s mother, sued Davis under 42 U.S.C. § 1983. Relevant here, she alleges that Davis’s use of deadly force violated J.R.’s Fourth Amendment rights. Davis asserted that he was entitled to qualified immunity. But the district court disagreed. We conclude that it was clearly established at the time of the shooting that a police officer couldn’t use deadly force against a fleeing suspect, even an armed one, who didn’t make a furtive or threatening movement with his weapon. So, we affirm the district court’s judgment. I. We recount the facts in the light most favorable to the plaintiff. Hensley ex rel. N.C. v. Price, 876 F.3d 573, 577 (4th Cir. 2017). A. In April 2020, South Carolina placed its residents under a stay at home and curfew order due to COVID-19. One evening during the lockdown, City of Columbia police 3 USCA4 Appeal: 25-1318 Doc: 46 Filed: 04/29/2026 Pg: 4 of 12 officer Kevin Davis responded to a report about teenagers riding bikes and looking into cars in a residential area. When Davis arrived at the neighborhood, he noticed J.R. walking alone down the sidewalk, with no bike in sight. Davis later claimed that he saw J.R. step behind a house and reap