BARNES v. FELIX
Application to Ohio Private Security Operations and Use-of-Force Decision-Making
Prepared by:
Commander T. Reed, OPOTA
Security & Law Enforcement Training
I. Purpose
Barnes v. Felix, 605 U.S. ___ (2025), provides important guidance concerning the judicial evaluation of an officer’s use of force. The United States Supreme Court unanimously reaffirmed that an excessive-force analysis must consider the totality of the circumstances, rather than limiting the review to the precise moment immediately preceding the application of force.
The decision is particularly valuable as a training and policy-development principle for security professionals because it reinforces the importance of evaluating the complete sequence of events surrounding a use-of-force incident.
II. Application to Ohio Private Security
Ohio private security personnel must understand that Barnes v. Felix does not independently grant private security officers the constitutional authority or police powers possessed by law-enforcement officers.
However, the decision provides a valuable framework for use-of-force training, incident assessment, supervisory review, and report writing.
Security personnel should evaluate the circumstances as a continuing sequence rather than viewing the incident exclusively from its final moment.
Relevant considerations include:
1. Initial Contact
The reason for the security officer’s contact with the individual and the circumstances that initiated the encounter.
2. Subject Conduct
The individual’s behavior, cooperation, resistance, aggression, threats, or other conduct throughout the encounter.
3. Security Officer Conduct
The actions taken by the security officer before and during the confrontation, including commands, positioning, physical contact, and attempts at de-escalation.
4. Escalation or Changes in Circumstances
Whether the situation escalated, de-escalated, or changed immediately before force was applied.
5. Available Alternatives
Whether reasonable alternatives were available under the circumstances, including disengagement, containment, obtaining assistance, verbal commands, or other appropriate measures.
6. Nature of the Threat
Whether the security officer reasonably perceived an immediate threat of physical harm and whether the level of force employed was appropriate to the circumstances confronting the officer.
7. Termination of Force
Once the need for force ceases, the security officer should discontinue the use of force when reasonably safe and appropriate to do so.
III. Totality-of-the-Circumstances Principle
The principal training lesson from Barnes v. Felix is that a use-of-force incident should not be evaluated by examining only the final split second.
The entire sequence of relevant events should be considered.
For security supervisors and investigators, this means that a post-incident review should examine the circumstances before, during, and immediately after the use of force.
IV. Ohio Legal Considerations
Ohio private security personnel must operate within the authority granted to them under applicable Ohio law, including the requirements governing private security services and applicable Ohio statutes concerning self-defense and defense of others.
Accordingly, Barnes v. Felix should be incorporated into Ohio security training as a decision-making and analytical principle, not as an expansion of a private security officer’s legal authority.
Security personnel should understand the distinction between:
– Private security authority
– Law-enforcement authority
– Self-defense
– Defense of another
– Protection of property
– Detention or arrest authority
– Use of physical force
– Use of deadly force
Each situation must be evaluated according to the officer’s lawful authority, the circumstances confronting the officer, applicable Ohio law, company policy, and the specific facts of the incident.
V. Training Standard
A professional Ohio security officer should continually ask:
«”What occurred before the force was used, what was occurring when force was used, what information was reasonably known at the time, and was the force reasonably necessary under the circumstances?”»
This approach promotes sound judgment, de-escalation, accountability, accurate reporting, and professional decision-making.
VI. Conclusion
Barnes v. Felix reinforces an important principle for security professionals:
A use-of-force incident should be evaluated in context—not through a narrow examination of only the final moment.
For Ohio private security, this principle should be incorporated into use-of-force policies, training programs, supervisory evaluations, incident investigations, and report-writing procedures, while recognizing that private security personnel remain subject to the specific limits of their legal authority under Ohio law.
Prepared for Professional Training and Policy Development
Commander T. Reed, OPOTA
Security & Law Enforcement Training
