Carnaby v. City of Houston

What This Case Is About

Carnaby v. City of Houston involves a fatal police shooting that followed a high-speed chase through Houston. Roland Carnaby, who claimed to be a CIA agent, fled from a traffic stop and was shot and killed by Houston police officers. His widow brought § 1983 claims alleging excessive force. The Fifth Circuit affirmed summary judgment for the defendants.

The Facts

In April 2008, Roland Carnaby was pulled over for speeding by Houston Police Department Officer Charles Starks. During the stop, Carnaby identified himself as a “CIA Agent.” Starks was suspicious and ran a background check, which revealed that Carnaby had a concealed handgun license and a prior arrest.

While Starks was still investigating, Carnaby fled the scene in his vehicle, initiating a high-speed chase through Houston. Multiple police units joined the pursuit. The chase ended when Carnaby’s vehicle came to a stop. Officers Charles Foster and Andrew Washington approached the vehicle.

According to the evidence — including police videos — Carnaby reached toward the passenger seat area where officers later discovered a loaded handgun. Officers Foster and Washington fired, killing Carnaby. A loaded pistol was found in his vehicle.

Susan Carnaby, Roland’s widow, filed suit under § 1983 against the City of Houston and the officers, alleging that the use of deadly force was excessive.

What the Court Decided

The Fifth Circuit affirmed summary judgment for the defendants.

On the excessive force claims, the court applied the Graham v. Connor objective reasonableness standard and the deadly force framework from Tennessee v. Garner. The court found that the officers reasonably believed Carnaby posed a serious threat of death or great bodily harm. He had fled from police at high speeds, was known to possess a concealed weapons permit, and reached toward an area of his vehicle where a loaded gun was later found. Under these circumstances, the use of deadly force was objectively reasonable.

The court also found the officers entitled to qualified immunity, as no clearly established law prohibited the use of deadly force under these circumstances.

On the municipal liability claim against the City, the court applied Piotrowski v. City of Houston and found no evidence of an official policy or custom that was the moving force behind the alleged violation.

Why This Case Matters for Your § 1983 Case

Carnaby v. City of Houston illustrates the legal standards governing deadly force:

• Deadly force is justified when the suspect poses a serious threat. Under Tennessee v. Garner, officers may use deadly force when they have probable cause to believe the suspect poses a significant threat of death or serious physical injury to officers or others.

• Flight plus weapons equals danger. A suspect who flees at high speed and reaches toward a weapon creates exactly the kind of imminent threat that justifies lethal force.

• Video evidence matters. Following Scott v. Harris, courts rely heavily on video footage when evaluating use-of-force claims, and a plaintiff’s account may be rejected when it is blatantly contradicted by the video.

• Municipal liability requires more than a single incident. Under Piotrowski, an isolated shooting, however tragic, does not establish municipal liability without evidence of an unconstitutional policy or custom.

Key Takeaway

When a suspect flees from police at high speed and reaches toward a weapon, officers are legally justified in using deadly force. Carnaby v. City of Houston confirms that the reasonableness of lethal force is judged based on what the officers knew at the moment they fired — not with the benefit of hindsight.