Ratliff v. Aransas County

What This Case Is About

Ratliff v. Aransas County addresses the use of deadly force against an armed suspect during a domestic violence call and demonstrates how qualified immunity protects officers who shoot a suspect after repeated commands to disarm — even when the suspect is later acquitted of criminal charges.

The Facts

At approximately 3:00 a.m. on March 24, 2015, Aransas County sheriff’s deputies Colby Scudder and Raymond Sheffield were dispatched to a residence in Rockport, Texas. Tanya Vannatter, Kenneth Ratliff’s fiancée, had called 911 reporting that Ratliff had beaten her — throwing her to the ground, punching her “everywhere,” and choking her until she thought she would die. She said Ratliff had been drinking “all day and all night.”

Vannatter was reluctant to press charges but asked the deputies to get Ratliff to leave voluntarily. As they approached the front porch, Ratliff began shouting, “Get the f*** off my property.” He was holding a loaded, semi-automatic pistol (though he had not chambered a round).

The deputies issued five commands to drop the weapon. Ratliff refused, responding “shoot me … shoot me” and “hey, you’re on my property.” The entire encounter lasted about twenty-five seconds. Deputy Scudder fired nine shots, hitting Ratliff five times. Ratliff survived.

Texas authorities charged Ratliff with aggravated assault on a police officer, but he was acquitted by a jury. Ratliff then sued both deputies and the county under § 1983.

What the Court Decided

The Fifth Circuit affirmed summary judgment for the deputies and dismissal of the county.

Deadly force was reasonable: Applying the Graham factors, the court found:

• Severity of the crime: The deputies responded to a violent domestic assault — a serious crime.
• Immediate threat: Ratliff was holding a loaded firearm and refused multiple commands to disarm. This posed an immediate, serious threat to the deputies’ lives.
• Resistance: Ratliff was actively resisting by refusing to drop his weapon and telling deputies to shoot him.

The deputies’ use of deadly force was objectively reasonable under these circumstances. The court emphasized that officers need not wait until a suspect actually fires before defending themselves.

Criminal acquittal is irrelevant: Ratliff’s acquittal on criminal charges did not establish that the force was unconstitutional. The standards for criminal conviction (beyond a reasonable doubt) and civil liability (objective reasonableness) are entirely different.

Municipal liability dismissed: Ratliff’s claims against Aransas County were dismissed at the pleading stage because he failed to plausibly allege a policy, custom, or failure to train that caused the violation under Monell.

Why This Case Matters for Your § 1983 Case

• Armed suspects face the highest threshold: When you are holding a weapon during a police encounter, the Graham factors almost always favor the officers. The presence of a firearm is the single most important factor in deadly force analysis.
• Commands to disarm are critical moments: If officers issue repeated commands to drop a weapon and you refuse, courts will view the subsequent use of force as reasonable. Each refused command strengthens the officers’ justification.
• “Shoot me” statements undercut your claim: Telling officers to shoot you can be interpreted as threatening behavior or evidence that you were creating the dangerous situation.
• Criminal acquittal ≠ civil victory: Being found not guilty of criminal charges does not mean officers violated your rights. Different legal standards apply.
• Twenty-five seconds is a long time for officers: The entire encounter lasted less than half a minute, but five commands were issued. Courts recognize that officers must make split-second decisions in rapidly evolving situations.

Key Takeaway

When officers encounter an armed, intoxicated suspect during a domestic violence call and issue multiple commands to disarm that are refused, deadly force is almost always deemed objectively reasonable under the Fourth Amendment. Criminal acquittal does not change this analysis, and qualified immunity will shield the officers from § 1983 liability.