Amicus Curiae Brief — Janice Hughes Barnes, Individually and as Representative of the Estate of Ashtian Barnes, Deceased, Petitioner v. Roberto Felix, Jr., et al.

No. 23-1239

In the

Supreme Court of the United States

JANICE HUGHES BARNES, INDIVIDUALLY

AND AS REPRESENTATIVE OF THE ESTATE

OF ASHTIAN BARNES, DECEASED,

Petitioner,

v.

ROBERTO FELIX, JR., et al.,

Respondents.

On Writ of Certiorari to the United States

Court of A ppeals for the Fifth Circuit

BRIEF OF AMICI CURIAE

CALIFORNIA STATE SHERIFFS’ ASSOCIATION,

CALIFORNIA POLICE CHIEFS ASSOCIATION,

AND CALIFORNIA PEACE OFFICERS’

ASSOCIATION IN SUPPORT OF RESPONDENTS

James R. Touchstone

Scott Wm. Davenport*

Richard A. Lucero

Jones & Mayer

3777 N. Harbor Blvd.

Fullerton, CA 92835

(714) 446-1400

swd@jones-mayer.com

Attorneys for Amici Curiae

California Sheriffs’ Association,

California Police Chiefs

Association, and California

Police Officers’ Association

* Counsel of Record

120151

A

(800) 274-3321 • (800) 359-6859

i

TABLE OF CONTENTS

Page

TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . i

TABLE OF CITED AUTHORITIES . . . . . . . . . . . . . . iii

I.

INTERESTS OF AMICI CURIAE . . . . . . . . . . 1

A. California State Sheriffs’ Association . . . . . 1

B. California Police Chiefs Association . . . . . . 1

C. California Peace Officers’ Association . . . . . 2

D. Amici Curiae Interests in This Matter . . . . 2

II. STATEMENT OF THE CASE . . . . . . . . . . . . . . 3

III. ARGUMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

A. The “Moment of Threat” Doctrine

is Constitutionally Sound and Does

Not Represent an Unconstitutional

Departure From Prior Authority . . . . . . . . 6

B. The “Moment of Threat” Doctrine

Properly Focuses on a Suspect’s

Violent or Threatening Behavior and

Preventing or Containing the Harm

from that Conduct . . . . . . . . . . . . . . . . . . . . . 8

ii

Table of Contents

Page

C. Amici Hold Accountability to the

Communities they Serve as a Core

Tenet of their Organizations . . . . . . . . . . . . 10

D. The “Moment of Threat” Doctrine

Neither Increases the Instances of

Excessive Force Nor Erodes Public

T r u st ; R at he r, it R e duc e s t he

Likelihood of Harm to Victims and Law

Enforcement Officers . . . . . . . . . . . . . . . . . . 12

E. The Universal Application of the

“Moment of Threat” Doctrine to

All Circuits Is Needed to Promote

Consistency of Outcome . . . . . . . . . . . . . . . 15

IV. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

iii

TABLE OF CITED AUTHORITIES

Page

Cases

Barnes v. Felix,

71 F.4th 393 (5th Cir. 2024) . . . . . . . . . . . . . . . . . . . . . 4

Cny. of Los Angeles v. Mendez,

581 U.S. 420 (2017) . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Graham v. Connor,

490 U.S. 386 (1989) . . . . . . . . . . . . . . . . . . . . . . . . 6, 7, 8

Scott v. Harris,

550 U.S. 372 (2007) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

State v. Olson,

92 Wn.2d 134, 594 P.2d 1337 (Wash. 1979) . . . . . . . . . 7

Tennessee v. Garner,

471 U.S. 1 (1985) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6, 8

Vos v. City of Newport Beach,

892 F.3d 1024 (9th Cir. 2018) . . . . . . . . . . . . . . . . . . . 15

Constitutional Provisions

U.S. Const. amend. IV . . . . . . . . . . . . . . . . . . . . . . . . . . 6, 8

iv

Cited Authorities

Page

Statutes and Rules

42 U.S.C. § 1983 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Supreme Court Rule 37.6 . . . . . . . . . . . . . . . . . . . . . . . . . 1

1

AMICI CURIAE BRIEF

IN SUPPORT OF RESPONDENTS

I.

INTERESTS OF AMICI CURIAE1

Amici are the above Associations, whose members

make up a vast array of law enforcement officers

throughout the State of California. Amici Members

represent policy making officials, management, and

rank and file officers, providing a broad spectrum of law

enforcement viewpoints.

A.

California State Sheriffs’ Association

The California State Sheriffs’ Association (“CSSA”) is

a nonprofit professional organization that represents each

of the fifty-eight (58) California Sheriffs. It was formed to

allow the sharing of information and resources between

sheriffs and departmental personnel, in order to allow for

the general improvement of law enforcement throughout

the State of California.

B. California Police Chiefs Association

The California Police Chiefs Association (“CPCA”)

represents virtually all of the more than 400 municipal

chiefs of police in California. CPCA seeks to promote

and advance the science and art of police administration

1. No party or counsel for a party authored this brief, in

whole or in part. No person or entity other than Amici Curiae,

its members, or its counsel made any monetary contribution to

the preparation or submission of this brief. This representation is

made in compliance with Rule 37.6 of the United States Supreme

Court Rules.

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and crime prevention, by developing and disseminating

professional administrative practices for use in the

police profession. It also furthers police cooperation and

the exchange of information and experience throughout

California.

C.

California Peace Officers’ Association

The California Peace Officers’ Association (“CPOA”)

represents more than 8,000 members who are peace

officers of all ranks throughout the State of California,

from municipal, county, state, and federal law enforcement

agencies. CPOA provides professional development and

training for peace officers, and reviews and comments on

legislation and other matters impacting law enforcement.

D.

Amici Curiae Interests in This Matter

This case raises important concerns for Amici, in that

it will determine critical issues potentially jeopardizing

the ability of Amici to intervene in dangerous situations,

negatively impact officer survival, cause confusion in law

enforcement use of force, and create a new theory for

bringing liability claims against local governments and

individual officers. Local law enforcement officers are

engaged in the primary activity of combating crimes and

frequently encounter dangerous situations and individuals.

Amici guide their conduct and agency operations by this

Court’s pronouncements, and their day-to-day lives and

those of the members of the communities they serve are

directly impacted by such decisions.

Since Amici represent the interests of a wide variety

of law enforcement, Amici provide this Court with a

valuable perspective into the potential adverse effects

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of the rejecting the “moment of threat” doctrine on a

nationwide scale and, indeed, the benefits of applying

such a doctrine universally. The underlying issues in this

case have the potential for wide-ranging changes on use

of force evidentiary and procedural principles at trial

and also have the potential to impact important public

safety concerns and law enforcement activities for all

levels of criminal investigation and the corresponding law

enforcement response.

Given the significant ramifications of this case, Amici

respectfully submit this brief in support of Respondents.

Amici’s independent perspective on the issues presented

in this case takes into account, in particular, the fact

that the members of Amici will be tasked with the actual

implementation internally and in the field of the legal

principles that this Court will determine in this matter.

II. STATEMENT OF THE CASE

The initiating circumstances regarding this officerinvolved shooting, while tragic, are neither unique nor

uncommon. While engaged in a traffic stop based on

vehicle code violations, circumstances changed in a splitsecond when a somewhat compliant suspect suddenly

engaged in unanticipated actions which placed the officer

in grave risk of imminent harm, requiring the officer to

discharge his service weapon in self-defense.

Specifically, on April 28, 2016, Officer Roberto Felix,

Jr., initiated a lawful traffic stop of a vehicle driven by

Ashtian Barnes. Officer Felix contacted Barnes and asked

for his driver’s license and proof of insurance. Barnes

turned off the vehicle and started “digging around” inside

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the car. At this moment, Officer Felix smelled marijuana

and asked Barnes to step out of vehicle.

At this point, Ashtian Barnes suddenly and inexplicably

turned the car back on and sharply accelerated. Finding

himself sandwiched in between Barnes’ vehicle, the

adjacent roadway divider, and the open door, Officer Felix

jumped onto the running board, drew his weapon, and

twice ordered Barnes not to move. Rather than complying,

Barnes continued accelerating with Officer Felix holding

on to the car for dear life. Officer Felix then fired his

service weapon, striking Barnes. These horrifying events

are captured on the patrol vehicle’s camera, rendering

them undisputed pursuant to Scott v. Harris, 550 U.S.

372, 380 (2007).

Barnes’ parents filed a claim under both 42 U.S.C.

§ 1983 and various state claims under Texas law. After

the case was removed to federal court, Felix moved

for summary judgment arguing that he did not violate

Barnes’ constitutional rights and was entitled to qualified

immunity. The district court granted summary judgment,

concluding that Officer Felix’s actions prior to the “moment

of threat”—including jumping on the door sill—had “no

bearing” on the use of force. See Barnes v. Felix, 71 F.4th

393, 396 (5th Cir. 2024). Thereafter, the Court affirmed

the grant of summary judgment, concluding that because

Barnes posed a threat of serious harm to Officer Felix the

moment the car began to move, Officer Felix’s use of force

was not excessive. Id.

In so ruling, the Fifth Circuit reasoned:

As the district court explained, we may only

ask whether Officer Felix was in danger “at

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the moment of threat” that caused him to use

deadly force against Barnes.” In this circuit,

it is well-established that the excessive-force

inquiry is confined to whether the officers or

other persons were in danger at the moment of

threat that resulted in the officers’ use of deadly

force. This “moment of threat” test means that

the focus of the inquiry should be on the act that

led the officer to discharge his weapon. Any of

the officers’ actions leading up to the shooting

are not relevant for the purposes of an excessive

force inquiry in this Circuit. (Internal citations

and quotations omitted, emphasis in original)

Id. at 397.

Conc u r r i ng i n t he de c i sion , Judg e Pat r ick

Higginbotham indicated that he felt constrained by the

“moment of threat” doctrine, lamenting that under this

doctrine, the Court was constrained from considering

Officer Felix’s actions in jumping on the car’s running

board and, instead, were limited such that their sole

consideration was “the act that led the officer to discharge

his weapon” rather than “what transpired up until the

moment of shooting itself.” Id. at 399 (J. Higginbotham,

concurring).

Finally, the Fifth Circuit noted that the “moment of

threat” doctrine represented a Circuit Split followed by

the Second, Fourth, Fifth, and Eighth Circuits while the

remaining Circuits did not follow such a rule. Id. at 400 (J.

Higginbotham, concurring). This Court granted certiorari

to resolve this split.

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III. ARGUMENT

A.

T he “ Moment of T h r e at” D o c t r i ne is

Constitutionally Sound and Does Not Represent

an Unconstitutional Departure From Prior

Authority

The words of the Fourth Amendment are clear: “The

right of the people to be secure in their persons, houses,

papers, and effects, against unreasonable searches and

seizures, shall not be violated. . . . ” (Emphasis added.)

Applying this in language in Tennessee v. Garner,

471 U.S. 1, 7 (1985), this Court ruled that apprehension

by the use of deadly force is a seizure subject to the

reasonableness requirement of the Fourth Amendment.

The Court noted that applying a balancing test, the focus

was whether the “totality of the circumstances” justified

a particular sort of search or seizure, the same balancing

test that should be applied to deadly force cases. Id. at

9. In that case, this Court noted that where the suspect

did not represent a threat to the officer—unlike the case

here—the use of deadly force would be unconstitutional.

Id. at 12.

Four years later, in Graham v. Connor, 490 U.S. 386

(1989), perhaps the seminal case on 42 U.S.C. § 1983, this

Court said, “with respect to a claim of excessive force,

the same standard of reasonable at the moment applies.”

Graham, 490 U.S. at 395 (emphasis added).

In this case, Petitioner argues that the “moment of

threat” constitutes an impermissible departure from

the Fourth Amendment’s reasonableness standard;

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and, conversely, Respondents assert that this doctrine

is constitutionally permissible. As is so often the case in

questions of this nature, the answer you get depends on

the question you ask. See State v. Olson, 92 Wn.2d 134,

141, 594 P.2d 1337 (Wash. 1979) (J. Dolliver, dis.) Here, the

“moment of threat” doctrine is not only constitutionally

permissible, it is absolutely consistent with this Court’s

prior case authority.

In Graham, this Court noted, “The reasonableness of

a particular use of force must be judged for the perspective

of a reasonable officer on the scene, rather than with

the 20/20 vision of hindsight.” Graham, 490 U.S. at 396.

Furthermore, “The calculus of reasonableness must

embody allowance for the fact that police officers are often

forced to make split-second judgments—in circumstances

that are tense, uncertain, and rapidly evolving.” Id.

By this language, Graham concluded that judges

should not be dissecting every decision an officer makes

on a frame-by-frame basis. Instead, the focus of the

Court’s inquiry should be narrowly directed toward the

suspect’s threatening actions and the officer’s response

thereto. The ability to watch body-worn video over and

over again punctuated by repeated pauses and rewinds,

and debating the significance of each micro movement,

deceives one into believing this is somehow possible for

peace officers to engage in while involved in rapidlyevolving incidents, functioning under the pressure of not

getting hurt themselves, and trying to prevent injury to

a community member.

The traditional standard, as articulated in Graham,

relies on reasonableness without the benefit of 20/20

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hindsight. The question is whether an officer’s actions

were reasonable, not whether better choices could have

been imagined after the fact, while not second-guessing

pre-force actions, pretending that officers should have

predicted all possible negative outcomes and simply

avoided escalation and violence as a matter of choice. The

practical implications of the approach promulgated by

Petitioner here is that peace officers would be dissuaded

from engaging with individuals to attempt to enforce

potential violations of the law for fear of being exposed

to civil liability. While this would constitute the ultimate

form of “de-escalation,” it is completely contrary to the

jobs that all peace officers have—promoting public safety.

B. The “Moment of Threat” Doctrine Properly

Focuses on a Suspect’s Violent or Threatening

Behavior and Preventing or Containing the

Harm from that Conduct

In recent years, however, many Courts have drifted

away from the plain language of the Fourth Amendment,

Garner, Graham, and common law, and began to focus

on the actions of the officers. Under this new theory, even

though an officer’s use of force may be justified at the

moment of the shooting, the officer is assessed for whether

they may have performed some action or inaction which

“escalated” the scenario so as to convert a reasonable

use of force into a constitutionally impermissible one.

This novel theory of “officer escalation,” however, was

never contemplated by the framers of the Constitution.

Even worse, this trend shifts focus away from the violent

conduct of the suspect and thrusts it upon the officer

who, acting with limited, often times inaccurate, and

constantly changing information, must omnisciently

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divine unpredictable threatening actions and escalating

threats in real-time. Suspects act. Peace officers react to

their actions.

Under this theory of “officer escalation,” if an officer’s

actions “unjustifiably” or “unnecessarily” created or

increased the risk of a deadly confrontation—even if

the subsequent force was reasonable at the time—the

officer should bear civil or criminal liability. However, the

problem is that for front-line officers trying to resolve a

critical incident, it is often impossible to determine what

will or will not later be determined to be unjustifiable or

unnecessary. Pre-force tactical decisions are necessarily

based on limited information, changing threat levels, and

exposure to personal physical harm, while taking place

in high-stress, potentially life-threatening situations.

Moreover, bizarre or unexpected reactions from a

suspect—such as attempting to start a car and flee from

a traffic stop based on vehicle code offenses—make it

impossible for officers to pre-determine all possible

outcomes in any given scenario.

This trend has created a potential legal minefield

where peace officers’ actions are reviewed not only for

their legality at the moment the decision to use force was

made, but every single discretionary tactical choice which

preceded the use of force. By engaging in such a hindsight

review, judges and juries may fail to appreciate the

complexities of real-time decision-making when presented

with an imminent fear of death or serious bodily injury.

The notion of officer escalation threatens to undermine

the standards that have long guided use-of-force

evaluations. By concentrating on the “moment of threat,”

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the Courts recognize the difficult, imperfect, highpressure decisions officers must make.

C.

Amici Hold Accountability to the Communities

they Serve as a Core Tenet of their Organizations

Amici hear and acknowledge the frustration Judge

Higginbotham expressed. As an initial response, Amici

remind the Court that accountability does not only occur

in the environment of civil litigation. In parallel with

litigation, a use of force can be subject to the internal

investigation and disciplinary process, force review

procedures, public disclosure of video and investigative

materials, and the risk that conduct could become the basis

for loss of certification to serve in the law enforcement

profession. Additionally, an officer can be subject to

criminal prosecution at the state or federal level.

Further, Amici point out this incident took place in

2016. In the years that have elapsed since that time, law

enforcement has continued to advance the mandates

of field delivery of mental health care, de-escalation,

utilization of less lethal weapon systems, and meeting

the needs of our diverse communities. Amici assure the

Court that these efforts will continue on into the future.

Amici do not, in any way, seek to avoid liability for any

errors members of their profession might commit. With

this as context, Amici must express the view that the

whole discussion of liability and the use of force standard

in the setting of this incident, fundamentally, is unsound.

Simply stated, the decision to stand on the car does not

transform the reasonableness of the subsequent use of

deadly force into a constitutional violation.

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In Cny. of Los Angeles v. Mendez, 581 U.S. 420 (2017),

this Court considered and rejected a similar analysis. In

that case, the Los Angeles County Sheriff ’s Department

received information that a parolee-at-large had been

observed at a certain residence. While other deputies

searched the main house, two deputies searched the back

of the property where plaintiffs were napping inside a

shack where they lived. When the deputies opened the

door of the shack, one of the plaintiffs rose from the bed

holding a BB gun. One deputy yelled, “Gun” and both

deputies immediately opened fire, shooting the individuals

multiple times. Id. at 423-425.

On the excessive force claim, the District Court found

that the deputies’ use of force was reasonable under

Graham, but held them liable nonetheless under the

Ninth Circuit’s provocation rule, which makes an officer’s

otherwise reasonable use of force unreasonable if (1) the

officer “intentionally or recklessly provokes a violent

confrontation” and (2) the provocation is an independent

Fourth Amendment violation. This ruling was affirmed

by the Ninth Circuit, which held, in the alternative, basic

notions of proximate cause would support liability even

without the provocation rule. Id. at 425-426.

In an 8-0 opinion, this Court vacated the Ninth

Circuit’s judgment holding that the Fourth Amendment

provided no basis for the Ninth Circuit’s “provocation

rule.” Id. at 423. In so holding, this Court noted that “A

different Fourth Amendment violation cannot transform

a later, reasonable use of force into an unreasonable

seizure.” Id.

This is exactly the type of outcome which the “moment

of threat” doctrine seeks to achieve. By focusing on the

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threatening actions of the suspect, this analysis rightly

concludes that a reasonable use of force is not transformed

into an unreasonable use based on the pre-force actions

of the officer.

D.

The “Moment of Threat” Doctrine Neither

Increases the Instances of Excessive Force

Nor Erodes Public Trust; Rather, it Reduces

the Likelihood of Harm to Victims and Law

Enforcement Officers

Petitioner, as well as multiple amici curiae who have

written in support of Petitioner, assert, without evidence,

that if this Court were to adopt the “moment of threat”

doctrine, a parade of horribles would result, including an

increase of instances of excessive force and an erosion of

public trust would occur. This level of distrust of our field

law enforcement officers is not warranted.

A key failure with Petitioner’s concentration on

pre-force conduct is determining exactly which actions

should be considered and what standard should apply.

Should courts require that pre-force conduct be reckless,

deliberate, or should mere negligent conduct which

unintentionally increases a risk be considered? Such

an inconsistent treatment leaves officers vulnerable to

varying interpretations of their actions. It also invites

absorbing subjective intent into use of force analysis, a

theory that has long been rejected.

Moreover, as “officer escalation” cases have increased,

officers have faced growing uncertainty about whether

their conduct will be deemed lawful. This unpredictability

erodes their confidence in making decisions in high-stress

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situations. Simply approaching a suspect, conducting a

traffic stop, or attempting to arrest someone can escalate

tensions. Routine interactions like confronting and

inquiring about possible criminal activity may predictably

increase the risk of violence, exposing officers to liability

for the very thing communities expect them to do. As an

aside, Amici remain concerned that the continued societal

pressure we place on our field law enforcement officers will

perpetuate difficulties in attracting the best candidates

to the profession and further diminish employee wellness.

Additionally, another significant concern is that the

concentration on “officer escalation” fails to consider the

human factors that impact law enforcement officers during

high-stress scenarios. Decisions in these types of critical

situations often involve split-second thinking relying on

training rather than the slow and deliberate analysis that

occurs in non-critical situations.

Expecting officers to engage in perfect decisionmaking in real-time disregards the perceptual and

cognitive performance issues of human physiology they

can face under stress, including narrowed vision, auditory

exclusion, and the dangers associated with reaction time

interpretation. Courts and juries have the luxury of

using post-event analysis, and can apply slow, analytical

thinking which does not reflect the reality of human

performance during life-threatening events. Failing to

account for these human factors may result in standards

that exceed what is realistically achievable.

Simply stated, law enforcement officers are human

beings, subject to the natural limitations of human

performance. This understanding is bypassed when the

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focus is upon pre-force tactics and alleged “escalation.”

And, accordingly, their conduct should be judged based

on the realities of their decision-making in high-stress,

rapidly evolving situations, rather than through the

video playback lens of unrealistic expectations or perfect

hindsight.

Moreover, expecting officers to predict every

possible outcome of their tactical decisions—and those

of their colleagues—could have a chilling effect, leading

to hesitation in life-or-death situations, which would

endanger both officers and their communities.

In order to fully understand the potential implications

for communities that could follow from the Court’s decision

in this matter, one can consider a regrettably frequent

request for law enforcement assistance. A department could

receive a 911 call with sounds of conflict in the background

but no one speaking on the phone. A subsequent call placed

back to the number goes unanswered. Officers respond

only to encounter what could be characterized as a cold

dark building. As experienced officers, having been to the

residence in the past, but recognizing their authority to

move forward is not as firm as they might have hoped, they

weigh the balance in favor of victim safety and enter the

location. Once inside, they encounter a domestic violence

victim with serious injuries and an enraged suspect armed

with a weapon. At such a critical moment for everyone’s

safety, the patrol officers would be instantly burdened by

the direction of this Court, and whether the path leading

them to these grim circumstances constrained how they

respond to the danger they all faced.

At the same time, under the same exact circumstances,

standing in front of the location in the middle of the

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night, with other calls pending, they might weigh the

ambiguity of the situation, with a cognizance of the

judicial instructions from this case, and feel they needed

to abandon any further intervention. In so doing, the

victim would be abandoned and forced to personally fend

off the assailant.

E. The Universal Application of the “Moment of

Threat” Doctrine to All Circuits Is Needed to

Promote Consistency of Outcome

In Vos v. City of Newport Beach, 892 F.3d 1024 (9th

Cir. 2018), the Ninth Circuit—which does not apply the

“moment of threat” doctrine—has concluded that the

events leading up to the use of force, including the officers’

pre-force tactics, are relevant to the reasonableness

analysis. However, in the Fifth District, the opposite rule

applies. See Barnes, 71 F.4th at 396.

Simply stated, whether a federal constitutional civil

rights violation has occurred should not be determined

by the zip code in which the altercation occurs. It defies

common sense that whether a federal constitutional

violation has occurred depends on whether one is located

in Manhattan’s Second Circuit or in Jersey City’s Third

Circuit just two miles and a short tunnel ride away.

However, where Amici breaks ranks with Petitioner is in

the assertion that the “moment of threat” doctrine should

not be applied at all; rather, Amici submits that this Court

should adopt and endorse the “moment of threat” doctrine

nationwide.

Because the “moment of threat” doctrine is consistent

with the United States Constitution, this Court’s prior

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precedent, keeps the focus on the suspect’s threatening

behavior rather than on officers’ pre-force actions and/or

alleged escalation, this Court should adopt and endorse

this doctrine nationwide.

IV. CONCLUSION

Accordingly, for all these reasons, Amici respectfully

request that the Court resolve the now-existing circuit

split and conclude that courts should apply the “moment

of threat” doctrine when evaluating excessive force claims

under the Fourth Amendment. This rule recognizes the

practical realities of modern day policing and ensures

victim, officer, and community safety.

Respectfully submitted,

James R. Touchstone

Scott Wm. Davenport*

Richard A. Lucero

Jones & Mayer

3777 N. Harbor Blvd.

Fullerton, CA 92835

(714) 446-1400

swd@jones-mayer.com

Attorneys for Amici Curiae

California Sheriffs’ Association,

California Police Chiefs

Association, and California

Police Officers’ Association

* Counsel of Record

DATED: December 20, 2024