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In a 1984 memo, Samuel Alito

wrote that “he saw no constitutional problem with a police officer shooting and killing an unarmed teenager who was fleeing after a $10 home burglary. ‘I think the shooting [in this case] can be justified as reasonable.’” A year later, the Supreme Court ruled 6-3 that the shooting represented an “unreasonable seizure,” and used the case to “set a firm national rule against the routine use of ‘deadly force’ against fleeing suspects who pose no danger.”

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