Selective Use of Ambiguous Body‑Camera Evidence in Deadly Force Cases:
Commentary on Juan Mendez v. City of Chicago (7th Cir. 2025)

I. Introduction

The Seventh Circuit’s decision in Juan Mendez v. City of Chicago, No. 24‑3110 (Dec. 3, 2025), addresses the use of deadly force by a Chicago police officer during a brief, chaotic foot pursuit and, centrally, how courts should treat body‑camera footage that is clear for some purposes and unclear for others.

Juan Mendez was shot three times by Officer Christian Szczur after a ShotSpotter alert led officers to his front porch in Chicago’s Austin neighborhood. Mendez, who had in fact fired a handgun shortly before, fled when approached, leading to an 18‑second chase that ended with his being shot and left paralyzed from the waist down. He brought a civil rights action under 42 U.S.C. § 1983, asserting excessive force in violation of the Fourth Amendment, and related Illinois state‑law claims against Officer Szczur and the City of Chicago.

The district court granted summary judgment for the defendants, holding that under the totality of the circumstances the shooting was objectively reasonable, and alternatively that qualified immunity would bar the § 1983 claim in any event. On appeal, the Seventh Circuit (Judge Scudder writing, joined by Judges St. Eve and Jackson‑Akiwumi) affirmed on the merits of the Fourth Amendment claim and, by extension, the state‑law claims, without needing to resolve qualified immunity.

The opinion is particularly important for two reasons:

It applies and synthesizes Supreme Court and Seventh Circuit precedent on Fourth Amendment deadly force, emphasizing that an officer may constitutionally use deadly force when he has probable cause to believe a suspect poses a threat of serious physical harm.
It develops a nuanced approach to body‑camera video at the summary judgment stage, articulating that video evidence is not legally “special” or infallible, but can resolve some factual disputes even when it is too unclear to resolve others.

These themes together make the case a significant refinement in the law of police use of force and the evidentiary treatment of video in § 1983 litigation within the Seventh Circuit.

II. Summary of the Opinion

A. Facts

In the early hours of May 26, 2018, while it was still dark, Juan Mendez fired a handgun outside his Chicago home. The Chicago Police Department’s ShotSpotter technology detected the gunshot and generated a radio alert for a shot fired near 5235 West Ohio Street.

Officers Christian Szczur and David Cook responded and arrived near the location within about two minutes. Officer Cook observed Mendez and a juvenile on a porch; no one else was visible in the area. Standing at the gate, Cook briefly spoke with them. Officer Szczur then joined, opened the gate, and approached, asking: “You guys don't have anything on you you're not supposed to have, right?” He instructed them to stand. Mendez remained seated and silent; as Szczur ascended the porch stairs, Mendez suddenly stood, jumped off the porch, cleared a fence, and fled down an alley.

Both officers gave chase. Before turning into the alley, Szczur yelled, “I'll shoot you.” As they ran, Officer Cook repeatedly shouted “Waistband,” followed by “Keep your hands up” and “Hands up,” and then “He's got it in his hand.” Mendez fell while running, allowing the officers to close the distance. He rose, looked back over his right shoulder, and as he did so, his right arm swung toward the officers with some object in his right hand.

Cook’s body‑camera footage confirms that Mendez was holding something, but the video is too grainy and dark to identify the object definitively. Immediately after shouting “I'll shoot you” a second time, Officer Szczur fired three shots. One bullet struck Mendez’s right shoulder; two struck his lower back. A gun landed about ten feet in front of Mendez as he fell. While lying wounded, Mendez stated, “I wasn’t going to shoot.” The shooting left him paralyzed from the waist down.

B. Procedural History

Mendez sued the City of Chicago, Officer Szczur, and Officer Cook in the Northern District of Illinois. His claims included:

A § 1983 claim alleging excessive force in violation of the Fourth Amendment against Officer Szczur;
An Illinois common-law battery claim against Officer Szczur; and
An indemnification claim against the City based on Officer Szczur’s actions.

Following discovery, both parties moved for summary judgment. The district court granted the defendants’ motion. Relying heavily on Cook’s body‑camera footage, the court found no Fourth Amendment violation under the totality of the circumstances and, in the alternative, held that qualified immunity would shield the officer. It also held that Mendez’s state‑law claims failed because they depended on the success of the federal excessive‑force claim.

Mendez appealed, challenging in particular the district court’s reliance on body‑camera footage that he argued was too unclear to defeat his version of events.

C. Holding

The Seventh Circuit affirmed. It held:

Under the totality of the circumstances, Officer Szczur had probable cause to believe that Mendez posed a threat of serious physical harm, making the use of deadly force objectively reasonable under the Fourth Amendment.
While the body‑camera footage was too unclear to prove that Mendez actually pointed a gun at the officers, it was clear enough to establish certain critical facts—specifically, that Mendez turned toward the officers with an object in his raised hand in a manner consistent with wielding a firearm—and to corroborate Szczur’s testimony about what he saw.
Because the Fourth Amendment claim failed on the merits, the Illinois battery claim (which requires “willful and wanton” misconduct by a public employee) also failed, and the derivative indemnification claim against the City necessarily fell with it.
The court therefore did not need to reach the qualified immunity ground relied upon in the alternative by the district court.

III. Detailed Analysis

A. Factual and Doctrinal Context

The opinion sits at the intersection of several ongoing developments in policing and civil rights law:

Technological developments: ShotSpotter technology triggered the initial police response, and body‑camera footage formed the backbone of the evidentiary record. The case illustrates how new technologies both create and constrain the record that courts later examine.
Deadly force and fleeing suspects: The case squarely implicates the rule of Tennessee v. Garner, which governs police use of deadly force to prevent escape when the suspect is believed to be dangerous.
Summary judgment in police shooting cases: The court’s analytical focus is as much on procedural posture—what a court may decide as a matter of law at summary judgment—as on substantive Fourth Amendment doctrine.

With this context, the Seventh Circuit takes a relatively officer‑protective view of the facts and doctrine, but simultaneously cautions against elevating video evidence to a privileged category.

B. Precedents and Authorities Cited

The court’s reasoning is built on a familiar but carefully updated set of precedents:

1. Barnes v. Felix, 605 U.S. 73 (2025)

The panel cites the Supreme Court’s decision in Barnes v. Felix for three core propositions:

Excessive force during a stop or arrest is analyzed under the Fourth Amendment.
The “touchstone” of the Fourth Amendment is objective reasonableness.
Reasonableness must be assessed under the “totality of the circumstances,” with “careful attention to the facts and circumstances” as they were known to the officer at the time.

Although these ideas trace back to Graham v. Connor and County of Los Angeles v. Mendez, Barnes is invoked as a recent Supreme Court restatement and integration of those principles. That framing underscores that the Seventh Circuit is following, not innovating upon, the Supreme Court’s basic Fourth Amendment structure.

2. County of Los Angeles v. Mendez, 581 U.S. 420 (2017)

The Supreme Court’s Mendez decision (no relation to the plaintiff here) is cited for its insistence on analyzing excessive force under a straightforward totality‑of‑the‑circumstances test, without overlaying additional “provocation” doctrines. The Seventh Circuit uses it, via Barnes, to reinforce:

That courts must look at all circumstances relevant to the officer’s decision to use force;
That the analysis focuses on what was known to the officer at the time of the force, not on hindsight or subsequent discoveries.

3. Graham v. Connor, 490 U.S. 386 (1989)

Graham is the foundational case establishing:

Claims of excessive force during seizures are governed by the Fourth Amendment’s objective reasonableness standard.
The inquiry is from the perspective of a reasonable officer on the scene, “rather than with the 20/20 vision of hindsight.”
Courts must attend to factors such as the severity of the crime, whether the suspect poses an immediate threat, and whether he is actively resisting or attempting to evade by flight.

The Seventh Circuit quotes Graham via Barnes, emphasizing “careful attention to the facts and circumstances” known to the officer. Those words are central to the court’s factual analysis of the 18‑second foot chase.

4. Tennessee v. Garner, 471 U.S. 1 (1985)

The court invokes Garner for the specific rule on deadly force:

“Where the officer has probable cause to believe that the suspect poses a threat of serious physical harm, either to the officer or to others, it is not constitutionally unreasonable to prevent escape by using deadly force.”

This is the crux of the Seventh Circuit’s holding. Once it concludes that Officer Szczur had probable cause to believe Mendez posed such a threat, the constitutional analysis essentially ends.

5. Rivas‑Villegas v. Cortesluna, 595 U.S. 1 (2021), and Estate of Biegert v. Molitor, 968 F.3d 693 (7th Cir. 2020)

Both cases are cited as reinforcing the Garner standard. Rivas‑Villegas, though a qualified immunity case, acknowledged the validity of the Garner rule while holding that the specific right there was not clearly established. Estate of Biegert similarly applies the “threat of serious harm” framework in a Seventh Circuit shooting case.

By pairing these cases with Garner, the Seventh Circuit signals that:

The key inquiry is whether the officer reasonably believed the suspect posed a serious threat at the moment deadly force was used.
This framework is stable and reaffirmed in recent Supreme Court and Seventh Circuit jurisprudence.

6. Video‑Evidence Precedents: Scott v. Harris, Kailin, Pam, Horton, Smith v. Finkley

The opinion devotes substantial attention to how courts should treat video evidence on summary judgment. The key cases are:

Scott v. Harris, 550 U.S. 372 (2007): The Supreme Court held that when a dash‑cam video “blatantly contradicts” the plaintiff’s version of events so that no reasonable jury could believe the plaintiff, a court should not adopt that version for purposes of summary judgment. The Seventh Circuit quotes Scott for:
- The rule that courts need view facts in the nonmovant’s favor only when there is a “genuine” dispute; and
- The standard for disregarding a version of events “blatantly contradicted” by the record.
Kailin v. Village of Gurnee, 77 F.4th 476 (7th Cir. 2023): Cited for the proposition that video can “eviscerate” a factual dispute only when it is sufficiently definitive that no reasonable disagreement is possible. Ambiguous video cannot, by itself, justify summary judgment.
Pam v. City of Evansville, 154 F.4th 523 (7th Cir. 2025): Used as a close analogue. There, video was “inconclusive” about whether the plaintiff literally raised a weapon before being shot but “conclusive” that he behaved in a manner consistent with wielding a firearm. The Seventh Circuit relies on this case to justify distinguishing between what video can and cannot definitively show.
Horton v. Pobjecky, 883 F.3d 941 (7th Cir. 2018): Quoted for caution that videos that are “unclear, incomplete, and fairly open to varying interpretations” cannot resolve evidentiary disputes at summary judgment.
Smith v. Finkley, 10 F.4th 725 (7th Cir. 2021): Example of a case where video was sufficiently open to interpretation that the court dismissed an interlocutory qualified immunity appeal, leaving the factual disputes for trial.

These cases collectively frame the court’s nuanced middle position: videos are powerful but ordinary evidence; their capacity to resolve factual disputes depends on their clarity and completeness, and they may be dispositive on some points while inconclusive on others.

7. Illinois State‑Law Cases: Ybarra and Tolliver

Ybarra v. City of Chicago, 946 F.3d 975 (7th Cir. 2020): Cited for the proposition that the Illinois Tort Immunity Act’s “willful and wanton” standard mirrors or is at least no lower than the Fourth Amendment reasonableness standard. If an officer’s conduct is reasonable under the Fourth Amendment, it cannot be willful and wanton.
Tolliver v. City of Chicago, 820 F.3d 237 (7th Cir. 2016): Cited for the idea that indemnification claims against a municipality fall when there is no underlying liability of the employee.

These authorities allow the court to dispose of the state‑law battery and indemnification claims in a short, derivative analysis once it has rejected the federal excessive‑force claim.

C. The Court’s Legal Reasoning

1. Fourth Amendment Framework: Objective Reasonableness and Totality of the Circumstances

The court begins its legal analysis by restating the governing standard:

Excessive force during a stop or arrest is controlled by the Fourth Amendment.
The question is one of objective reasonableness, not the officer’s subjective intentions or hindsight judgments.
The court must look to the totality of the circumstances, focusing on what the officer knew at the time of the force.

Within that framework, the decisive doctrinal test, drawn from Garner, is:

Was there probable cause to believe Mendez posed a threat of serious physical harm to the officers or others at the moment Officer Szczur fired?

If the answer is yes, then, as the court puts it, “it is not constitutionally unreasonable to prevent escape by using deadly force.”

2. Application: Why the Court Finds Probable Cause to Believe a Serious Threat Existed

The court’s application of the objective reasonableness test proceeds by layering facts and inferences known (or reasonably knowable) to the officers at the time:

Nature of the underlying event: The officers were responding to a ShotSpotter alert indicating that a gun had been fired in the vicinity mere minutes earlier. Even though the court does not explicitly rely on the separate fact that Mendez was the one who fired, the officers reasonably believed they were investigating a recent gunshot in a residential neighborhood in the dark.
Initial encounter on the porch: The situation involved only Mendez and a juvenile, with no one else visible. When asked whether they had anything they were not supposed to have and told to stand, Mendez did not answer and instead abruptly fled by jumping off the porch, over a fence, and into an alley. This evasive conduct in response to an inquiry about contraband (immediately after a gunshot alert) reasonably heightened suspicion.
Flight and contemporaneous warnings: During the brief chase, Officer Cook repeatedly shouted “Waistband” and ordered “Hands up.” He then yelled “He’s got it in his hand.” These shouted observations, heard by Szczur as he pursued, reasonably suggested that Mendez was armed and drawing or holding a weapon as he fled.
Mendez’s movements immediately before the shooting: The key sequence was that Mendez fell, rose, and looked back over his right shoulder toward the officers. As he turned, his right arm swung in their direction with an object in his hand. Even though the video cannot definitively show that the object was a gun, it clearly shows that he was holding something and moving his arm toward the officers.
Corroboration by what followed: After the shots, a gun landed about ten feet in front of Mendez, and he stated, “I wasn’t going to shoot.” While the reasonableness analysis must be anchored in what the officer knew before firing, these facts corroborate the officers’ perception that Mendez was armed.

Putting these circumstances together, the court concludes that a reasonable officer in Szczur’s position would have had probable cause to believe that Mendez posed a serious threat of physical harm. The combination of:

a recent gunshot alert,
flight after a question about weapons,
contemporaneous “waistband” and “he’s got it” warnings, and
a suspect turning back with an object in hand in the officers’ direction

creates, in the court’s view, an objectively dangerous scenario. Within the split seconds available, deadly force to prevent what appeared to be an imminent armed confrontation was, under Garner, constitutionally reasonable.

3. The Treatment of Body‑Camera Evidence

A central dispute on appeal was the proper use of Officer Cook’s body‑camera footage. Mendez argued that the video was too dark, shaky, and rapid to support reliance on it at summary judgment, particularly with respect to what he was doing with his hands in the moments before he was shot.

The Seventh Circuit agrees in part, but only in part:

The court accepts that the footage is “too unclear to establish that Mendez had pointed a gun at the officers.”
However, it holds that the footage is clear enough to establish that:
- Mendez ran away and fell;
- he got back up and turned toward the officers;
- his right arm swung in their direction; and
- he was holding some object in his right hand.
The video thus corroborates Szczur’s testimony that he perceived Mendez as turning toward them with an object in his hand consistent with a firearm.

The court then articulates a careful doctrinal position about video evidence:

No “special status” for video: The court emphasizes that video evidence “enjoys no special status in law by virtue of being video evidence. It is not infallible.” This is a direct response to readings of Scott v. Harris that treat video as uniquely dispositive.
Standard from Scott v. Harris applies to all evidence: Courts may refuse to accept a party’s version of the facts only when that version is “blatantly contradicted by the record” such that no reasonable jury could believe it. Any type of evidence—including, but not limited to, video—can “blatantly contradict” a story.
Unclear videos cannot resolve disputes: When videos are “unclear, incomplete, and fairly open to varying interpretations,” they cannot decisively resolve disputed facts short of trial. This echoes Horton and Kailin, and the court insists that this rule “does not change today.”
Different clarity for different purposes: The novel articulation appears here: “a video can be unclear for one purpose and clear for another.” Relying on Pam, the court explains that even if a video cannot show whether a suspect literally raised a weapon, it can still conclusively show that the suspect behaved in a manner consistent with wielding a firearm. Thus, partial clarity can narrow, even if it does not eliminate, factual disputes.

In Mendez, this doctrinal stance means:

The court cannot say the video proves Mendez pointed a gun directly at the officers.
But it can and does say that the video forecloses any reasonable inference that he turned back toward the officers with empty hands or with movements inconsistent with drawing or wielding an object.

Given that the court still must view the evidence in the light most favorable to Mendez, the decisive move is its determination that even the most plaintiff‑friendly interpretation, consistent with the video, still leaves only one reasonable conclusion under Garner: an objectively reasonable belief that Mendez posed a serious threat.

4. Disposition of the State‑Law Claims

Once the court finds no Fourth Amendment violation, the state‑law claims fall quickly.

a. Illinois Battery and “Willful and Wanton” Conduct

Under 745 Ill. Comp. Stat. 10/2‑202, a public employee is not liable for acts or omissions in enforcing the law “unless such act or omission constitutes willful and wanton conduct.”

Drawing on Ybarra, the Seventh Circuit reasons that:

If an officer’s use of force is objectively reasonable under the Fourth Amendment, it cannot simultaneously be “willful and wanton” under Illinois law.
“Willful and wanton” in this context connotes a higher degree of culpability than mere negligence—something akin to reckless disregard for safety—whereas here the court finds that the officer reasonably believed he was confronting a serious threat.

Because the same set of facts making the force reasonable under federal law also negate the mental state necessary for willful and wanton conduct, the Illinois battery claim necessarily fails.

b. Indemnification by the City of Chicago

The indemnification claim against the City is parasitic on Officer Szczur’s liability. As Tolliver makes clear, a municipality’s duty to indemnify under Illinois law is contingent on the underlying liability of the employee.

With no liability for Szczur—under either federal or state law—the indemnification claim “falls away too.”

D. Impact and Implications

1. Refinement of Video‑Evidence Doctrine

The most lasting doctrinal contribution of Mendez is likely its articulation of how courts should treat ambiguous body‑camera footage:

It rejects any notion that video evidence is categorically privileged or that courts may routinely sidestep jury trials simply because some video exists.
At the same time, it allows courts to parse videos more granularly, treating some aspects as definitively established while leaving other aspects open to dispute.
The notion that a video may be “unclear for one purpose and clear for another” gives trial courts a vocabulary and framework to write more nuanced summary judgment opinions in cases with imperfect video evidence.

In practice, this may:

Encourage courts to undertake a frame‑by‑frame, fact‑specific analysis of what videos do and do not show; and
Make it both easier and harder, depending on the case, for plaintiffs to survive summary judgment—easier where key facts remain indeterminate on video, harder where even partial clarity undermines the plaintiff’s narrative.

2. Continued Deference to Split‑Second Deadly Force Decisions

Substantively, Mendez underscores the high level of deference courts may give officers’ split‑second judgments in potentially armed encounters:

The entire foot chase lasted about 18 seconds from flight to shooting.
It was dark, in a residential neighborhood, shortly after a gunshot alert.
The suspect was fleeing, ignoring commands, and making movements consistent with drawing or wielding a weapon.

In such contexts, the court reaffirms that the threshold for “probable cause to believe” a threat of serious harm exists is not so high as to require certainty, or even clear visual confirmation, that a gun is pointed at the officer. It is sufficient that, in real‑time, the suspect’s behavior is reasonably perceived as posing an imminent armed threat.

For future cases, this suggests that:

Plaintiffs will face an uphill battle challenging deadly force used in response to suspicious hand‑to‑waistband movements and turning motions in the context of a suspected gun crime.
Courts are likely to continue reading Garner as allowing substantial leeway where officers confront rapidly developing, potentially lethal situations, especially with some corroborating evidence of a weapon.

3. State‑Law Claims Tracking Federal Outcomes

As in Ybarra, the court effectively ties the fate of related Illinois tort claims to the outcome of the federal excessive‑force analysis. When the Fourth Amendment standard is met, Illinois’s “willful and wanton” standard will rarely, if ever, be satisfied.

The practical result is that:

In police shooting cases within the Seventh Circuit, success or failure on the § 1983 claim will typically determine the outcome of parallel Illinois assault, battery, or negligence theories against the officer.
Indemnification actions against the City of Chicago will often rise or fall with the officer’s underlying liability, reducing the possibility of municipal exposure absent individual officer liability in this category of cases.

4. Interplay with New Supreme Court Guidance (Barnes v. Felix)

By repeatedly citing Barnes v. Felix, the Seventh Circuit signals alignment with the Supreme Court’s current articulation of the excessive‑force framework. Even though Barnes largely restates earlier law, its presence in this opinion:

Anchors the analysis in a recent Supreme Court case, reinforcing doctrinal continuity; and
May discourage lower courts from innovating beyond the established totality‑of‑circumstances, objective‑reasonableness approach in deadly force cases.

5. Qualified Immunity in the Background

Although the district court relied on qualified immunity in the alternative, the Seventh Circuit did not. Instead, it resolved the case on the merits by holding that no constitutional violation occurred.

This choice has two implications:

Normatively: Deciding on the merits rather than on qualified immunity provides clearer guidance to officers and litigants about what the Constitution requires. It avoids the criticism that qualified immunity can obscure whether conduct is lawful.
Practically: By holding that the use of force was constitutional, rather than merely not “clearly established” as unconstitutional, the court sets a more robust precedent that other officers can rely on.

IV. Explaining Key Legal Concepts

For readers less familiar with constitutional and civil rights law, several core concepts in the opinion merit brief clarification.

1. 42 U.S.C. § 1983

Section 1983 is a federal statute that allows individuals to sue state and local officials (including police officers) for violating their federal constitutional or statutory rights while acting “under color of” state law. It does not create rights itself; it provides a vehicle for enforcing rights found elsewhere, such as the Fourth Amendment.

2. Fourth Amendment “Objective Reasonableness”

When a person claims that police used excessive force in a seizure (e.g., during an arrest or stop), courts look to the Fourth Amendment, which protects against “unreasonable searches and seizures.” Under Graham v. Connor:

The question is not whether the officer acted with good or bad intent, but whether the amount of force used was objectively reasonable from the perspective of a reasonable officer on the scene.
Courts consider the totality of the circumstances, including:
- Severity of the suspected crime;
- Whether the suspect posed an immediate threat to the officer or others;
- Whether the suspect was actively resisting or attempting to flee.

3. “Probable Cause to Believe” a Threat of Serious Harm (Garner)

In deadly force cases, Tennessee v. Garner adds a more specific rule: an officer may use deadly force to prevent escape only if he has probable cause to believe the suspect poses a threat of serious physical harm to the officer or others.

“Probable cause” here means there is a reasonable basis—based on facts and reasonable inferences—to believe a serious threat exists. It does not require certainty, and it is evaluated from the officer’s perspective at the time, not by later, clearer evidence.

4. Summary Judgment and “Genuine Disputes” of Material Fact

Summary judgment is a procedural device that allows a court to resolve a case without trial when:

There is no genuine dispute as to any material fact; and
The moving party is entitled to judgment as a matter of law.

A “genuine” dispute exists if a reasonable jury could return a verdict for either side based on the evidence. At this stage, courts typically view the evidence in the light most favorable to the nonmoving party (here, Mendez). However, under Scott v. Harris, if the nonmovant’s version is “blatantly contradicted” by the record—such as clear video footage—so that no reasonable jury could believe it, courts need not accept that version.

5. Body‑Camera Evidence

Body‑camera videos are simply one type of evidence. They can be powerful, but they are not inherently superior to other evidence and may be:

Unclear (e.g., grainy, dark, or obstructed);
Incomplete (failing to capture everything relevant);
Open to multiple reasonable interpretations.

In Mendez, the court stresses that videos must be evaluated like any evidence. They may definitively resolve some factual questions (e.g., whether the suspect was running, where his arm was raised) while leaving others unresolved (e.g., precisely what object he held).

6. Illinois “Willful and Wanton” Conduct

Under 745 Ill. Comp. Stat. 10/2‑202, public employees (including police officers) are immune from liability for acts or omissions in the “execution or enforcement of any law” unless their conduct is “willful and wanton.”

“Willful and wanton” generally denotes a conscious disregard or utter indifference to the safety of others—more than negligence, closer to recklessness. When a court finds that an officer’s use of force was objectively reasonable under the Fourth Amendment, it almost necessarily follows that the conduct was not willful and wanton, as Mendez confirms.

7. Municipal Indemnification

Illinois law generally requires municipalities to indemnify their employees for judgments entered against them for acts within the scope of their employment. But indemnification is derivative: if the employee is not liable, there is no judgment to indemnify.

In Mendez, because the officer is found not liable under both federal and state law, the indemnification claim against the City of Chicago “falls away.”

V. Conclusion

Juan Mendez v. City of Chicago fits within a well‑established line of cases governing police use of deadly force but refines the law in two important ways.

First, it reaffirms and concretely applies the Garner/Graham/Barnes framework: an officer may constitutionally use deadly force when, based on the totality of the circumstances known at the time, he has probable cause to believe the suspect poses a threat of serious physical harm. In a dark alley, moments after a reported gunshot, with a suspect fleeing, ignoring commands, and turning back with an object in his hand, the Seventh Circuit holds that threshold is met as a matter of law.

Second, it articulates a nuanced approach to body‑camera evidence. Rejecting any special evidentiary status for video, the court emphasizes that videos, like other evidence, can both clarify and obscure. A video may be too ambiguous to prove that a suspect literally pointed a gun, yet clear enough to establish that he moved his arm with an object in a manner consistent with wielding a firearm. Courts may rely on these partially clear aspects to grant summary judgment when no reasonable jury could find the force excessive under the established Fourth Amendment standards.

By aligning state‑law claims with the federal reasonableness determination and choosing to decide the case on the merits rather than on qualified immunity, the court provides meaningful guidance for officers, litigants, and lower courts. Mendez thus stands as a significant precedent in the Seventh Circuit on both the substance of deadly force law and the methodology for evaluating body‑camera footage in civil rights litigation.

Selective Use of Ambiguous Body‑Camera Evidence in Deadly Force Cases: Commentary on Juan Mendez v. City of Chicago (7th Cir. 2025)