Supreme Court of the United States / October Term 2020

Lombardo v. St. Louis

Decided June 28, 2021. The Court ruled per curiam — an unsigned opinion of the Court.

Docket 20-391 · 594 U.S. 464 (2021) · Cited 131 times

Holding

Because it is unclear in this excessive force case whether the Eighth Circuit incorrectly thought the use of a prone restraint is per se constitutional so long as an individual appears to resist officers’ efforts to subdue him, the Eighth Circuit’s judgment is vacated, and the case is remanded to give the court the opportunity in the first instance to employ the careful, context-specific analysis required by this Court’s excessive force precedent.

The Court’s statement of the holding, from the opinion’s syllabus. The syllabus is prepared by the Reporter of Decisions and is not part of the opinion of the Court — read the official opinion for authority.

Precedents cited

Supreme Court decisions this opinion relies on, ordered by how often it cites each. Cases in our collection link through; others are named.

Official text

Read the official opinion (PDF, supremecourt.gov)

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Source: Supreme Court of the United States, slip opinions (2021). Citation count from the Free Law Project’s CourtListener bulk data. Data last verified 2026-07-03. Informational only; verify against the primary source before relying. Not a consumer report (FCRA).