The Supreme Court Just Decided a Major Issue in Cases Like Renee Good’s Shooting

The Supreme Court Just Decided a Major Issue in Cases Like Renee Good’s Shooting—and Not How You Might Expect

The Supreme Court Just Decided a Major Issue in Cases Like Renee Good’s Shooting—and Not How You Might Expect

Cynthia Lee

Thu, January 15, 2026 at 8:03 PM UTC

8 min read

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After federal agents killed an unarmed American citizen in broad daylight last week, high-ranking government officials rushed to defend the shooter, framed a mother’s attempt to escape an escalating confrontation as “domestic terrorism,” and blamed the victim for her own death. The killing of Renee Good is not just a failure of policing—the public response by those in power should alarm every American who believes that being frightened by armed agents and trying to drive away should not be a capital offense. Indeed, recent Supreme Court precedent illuminates why the shooting of Good by Immigration and Customs Enforcement agent Jonathan Ross is not the case of self-defense that administration officials are suggesting. The totality of events—which has been the standard established by the court since 1989 and was reaffirmed just last year—suggests that it was not reasonable for Ross to shoot Good in the head as she was attempting to drive away from ICE agents trying to forcibly remove her from her car.

Last week, Ross fatally shot 37-year-old Renee Nicole Good, a white mother of three, while she was in her SUV, apparently attempting to leave a situation that was becoming increasingly hostile. In cellphone video of the incident, we can see two ICE agents exit a pickup truck and approach Good’s car. As one agent appears to reach through the driver’s open window and tries to open the door, Good slowly reverses, then turns towards the right and drives forward slowly, attempting to leave. At that moment, a third officer, who is standing in front of Good’s car, unholsters his gun and, while moving to the side of the vehicle, fires several shots inside, striking Good in the head. The car continues to move forward and crashes into a parked car. Good was pronounced dead shortly after.

Department of Homeland Security Secretary Kristi Noem defended the agent who shot Good, saying, “This was an act of domestic terrorism. ICE officers got stuck in the snow and were attempting to push out their vehicle when a woman attacked them.” President Donald Trump also weighed in immediately after the killing, writing on Truth Social, “The woman screaming was, obviously, a professional agitator, and the woman driving the car was very disorderly, obstructing and resisting, who then violently, willfully, and viciously ran over the ICE Officer, who seems to have shot her in self defense.” None of the videos that have emerged from the shooting show Good running over the agent or attacking agents prior to her death.

Good was a U.S. citizen, and DHS has stated she was not a target of an ICE investigation. She was shot just blocks from her home.

Another video of the incident follows what happened before the agents approached Good’s SUV. In the video, Good extends her arm from the open driver’s window and makes the “Go ahead” signal to a pickup truck that has just pulled up and stopped a few feet from her car, right before ICE agents exited the vehicle. The footage suggests that Good was not attempting to block agents with her car, as some have claimed.

A third video, taken from the cellphone of the agent who shot Good, features a smiling Good, with her car window rolled down, saying, “That’s fine, dude. I’m not mad at you.” It also shows a woman, later identified as Becca Good, Good’s wife, outside the car, filming the ICE agent. As the agent is filming the license plate of their car, Becca says, “That’s OK, we don’t change our plates every morning, just so you know. It’ll be the same plate when you come talk to us later.” A few seconds later, two agents approach the SUV, one trying to open the driver’s-side door, while yelling, “Get out of the fucking car!” Possibly frightened at what appears to be a hostile situation, Good puts the car in reverse, then drives forward. The camera suddenly points towards the sky, and we hear a thud. Three shots ring out, one immediately after the other. After that, we hear a male voice saying, “Fucking bitch.”

The government has claimed that the agent who shot Good was in fear for his life and was acting in self-defense. The videos illustrate something else: an avoidable tragedy. Again, recent Supreme Court precedent helps explain why.

In assessing whether a law enforcement agent’s use of deadly force was reasonable or excessive, the court this past summer rejected the 5th Circuit’s narrow “moment of threat” doctrine—which stated that the only thing that matters in determining whether an officer reasonably fears for their life in a use-of-force situation is the moment of the shooting itself—as inconsistent with the Fourth Amendment. The court, in Barnes v. Felix, rejected this narrow time-framing approach and repeated what it had held in Graham v. Connor: In assessing the reasonableness of an officer’s use of force, one must consider the totality of circumstances.

Many of those defending the shooting appear to be focusing on the moment just before he fired the first shot. Applying a moment-of-threat approach to this shooting would require one to freeze-frame the video at the moment the officer was standing in front of Good’s car and saw it inching forward. Under such a cramped view of the incident, one might conclude that in that moment, the officer feared for his life and therefore needed to shoot to defend himself.

In contrast, if we broaden the time frame and consider that the agent put himself in front of the vehicle, that a smiling Good had, seconds earlier, told the agent, “That’s fine, dude, I’m not mad at you” and started to move her car forward only after other agents approached her vehicle, with one reaching in through the open window, trying to open the driver’s side door, and screaming for her to get out of the “fucking car,” the claim that the agent needed to shoot Good to save his life seems less plausible. That the agent was able to stay on his two feet, move to the side of the car, and fire two shots into the open driver’s-side window as Good was turning the SUV to the right and trying to drive away further undermines the claim that he acted in self-defense to neutralize an imminent threat to his life. The videos suggest that Good was simply trying to leave what was becoming an increasingly hostile situation, not purposely trying to hit the ICE agent who had dangerously put himself in front of her car.

One question the court left open in Barnes was whether it is appropriate to consider prior conduct of law enforcement that increases the risk of an encounter with a civilian turning deadly—something many have called “officer-created jeopardy.” It seems obvious that if one is applying a totality-of-the-circumstances approach, then prior conduct of law enforcement that increases the risk that the encounter will turn deadly is just part of the totality of the circumstances and ought to be part of the inquiry.

Some have pointed out that putting oneself in front of a moving vehicle is not considered a wise police practice. Similarly, shooting into a moving vehicle is not considered a good police practice unless necessary to stop an armed or dangerous felon (neither of which accurately describes Good), because of the risk of injury to the occupant of the vehicle and nearby bystanders. Although the first shot appears to have gone through the car’s front windshield, the second and third shots seem to have been fired by the agent at Good’s head through the open driver’s-side window as she was trying to leave. The officer by that time was firing from the side of the vehicle, not shooting someone trying to run him over as has been claimed. If he simply wanted to stop the vehicle from escaping, why did he aim at the driver’s head rather than the tires of the SUV?

In discussing the shooting, Noem said, “Any loss of life is a tragedy, and I think all of us can agree that, in this situation, it was preventable,” suggesting it was Good’s own fault that she had been shot. Similarly, Vice President J.D. Vance has said that Good’s death was “a tragedy of her own making.” With these comments, Noem, Vance, and others defending the officer posit that if Good had simply followed orders and gotten out of the car, none of this would have happened.

Ironically, Good’s death was completely preventable, not because Good failed to comply with the order to exit her car but because the officer could have exercised restraint and refrained from shooting her. He had taken a video of her license plate number, so if the agency wanted to track her down, it could have done so later. When the agent fired two shots into the open driver’s-side window from the side of Good’s car, Good was not posing an imminent threat of death or serious bodily injury to him or any other agent. Good was not a violent felon trying to flee the scene of a crime. She was just trying to get home to her three kids in one piece.

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