"As Lyons struggled for air, the officer handcuffed him, but continued to apply the chokehold until he blacked out. When Lyons regained consciousness, he was lying face down on the ground, choking, gasping for air, and spitting up blood and dirt. He had urinated and defecated. He was issued a traffic citation and released."

In *City of Los Angeles v. Lyons*, the Supreme Court reversed a ban on police chokeholds holding that Lyons did not establish a real and immediate threat that he would be stopped again in the future by the police, who without justification or provocation, would again apply a chokehold. Despite the fact that between 1975 and 1980, the LAPD had used chokeholds over 975 times, killing 16 people including 12 Black men, the Court held that Lyons needed to prove that LA police officers always used chokeholds in these encounters or that the City expressly ordered them to do so in order to uphold the ban. This case reinforced the unreasonably high threshold at which the Courts will intervene to prevent police violence.

Death at the hands of law enforcement remains a serious human rights issue, and Black men suffer disproportionately, with a 1 in 1,000 chance of being killed by police. While civilians can attempt to sue the police for damages, qualified immunity is still upheld at the highest levels, protecting police officers from facing consequences for their actions, and high thresholds remain for injunctive relief.