Justification of the use of deadly force via the "fleeing felon" rule can be traced to:

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The justification for using deadly force against a fleeing felon can be traced back to English Common Law, which allowed law enforcement to use any necessary means to prevent an escaped prisoner from fleeing. This principle was later adopted by American law enforcement agencies and was used as a justification for using deadly force against fleeing suspects until the Tennessee v. Garner case in 1985, which established stricter guidelines for the use of deadly force. The Graham v. Conner case in 1989 further clarified the use of force standards in law enforcement. The FLETC guidelines only provide training and best practices for law enforcement agencies and do not establish legal justifications for the use of deadly force.

Justification of the Use of Deadly Force Via the "Fleeing