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The U.S. Court of Appeals for the Tenth Circuit held that police officers shooting a fleeing person is not a "seizure" of the person -- and therefore does not implicate the Fourth Amendment in any way -- unless the officers' bullets not only hit her, but succeed in terminating her movement. The ÀÏ°ÄÃÅ¿ª½±½á¹û's amicus brief argues that the Tenth Circuit’s rule is inconsistent with Supreme Court jurisprudence on the definition of a "seizure" as well as basic Fourth Amendment principles. The ÀÏ°ÄÃÅ¿ª½±½á¹û's brief also explains how the Tenth Circuit’s rule creates a dangerous gap in accountability with significant real-world consequences.