Arnold v. City of Olathe, Kansas

Officers used reasonable force when they shot and killed woman brandishing a gun at them after an extended standoff with hours of negotiations; court recognizes that it is proper to consider whether an officer’s reckless or deliberate conduct “immediately connected” to the use of force created the need to use deadly force, although noting that the Supreme Court has not decided that issue, finding that the officers’ behavior here did not create the need to use deadly force either because it was too attenuated or was not reckless; court finds no case law establishing that it is a violation of a constitutional right not to consider the mental condition of a subject of force.