Farrell v. Montoya, 878 F.3d 933 (10th Cir. 2017): In this appeal from the district court's denial of summary judgment on plaintiff's excessive force claim in a Section 1983 civil rights case, the Tenth reverses. In this case, which made the internet, NM State Police officers fired shots into plaintiff's minivan, in which five children were passengers, thankfully not hitting any of them. The Tenth Circuit held that, because the defendant was fleeing the officers when they fired the shots, she and her passengers were not "seized" at the time because they were not submitting to the officers' authority. "As there was no seizure, there was no unreasonable seizure, even if [Officer] Montoya was using deadly force." In short, if you're running away, officers get a free shot.