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ACLU-MO History Spotlight: Police Use of Deadly Force

Mattis Case

In 1971, two teenagers—Michael Mattis (age 17) and Tomas Rolf (age 18)—were found in a golf course shed in St. Louis County. Police responded to a burglary call. In the dark, police officer Richard Schnarr ordered Mattis to stop, then fired a shot, which struck his head and killed him.

Newspaper clipping with an article headline reading "Warning shots allowed in some municipalities"
Newspaper clipping about police policy on gun use, 1971. From the ACLU-MO Records (wua00355).

The ACLU of Eastern Missouri helped Dr. Robert Mattis and his wife, Christine, sue for the wrongful death of their son. In 1977, the 8th Circuit Court ruled in Mattis v. Schnarr that police use of deadly force against any fleeing felon was unconstitutional.

Although the Supreme Court overturned the Mattis case on procedural grounds, the 8th Circuit’s extensive review of police practices provided useful in Tennessee v. Garner in 1985.

Open book with margin notes
“Is killing peace?” Eugene Buder adds notes to this brief, in preparation for the appeal to the Supreme Court in October 1976. From the ACLU-MO Records (wua00355), Series 3.

In 1985, the Supreme Court ruled that using deadly force to apprehend a fleeing suspect who was not otherwise dangerous violated the Fourth Amendment’s requirement for reasonable seizures.

Tracking the Problem

Working to end police use of violence against the community has long been a goal of the ACLU-MO.

This slideshow includes newspaper clippings (1968–1981) from three folders in the ACLU-MO’s archive. It represents only a fraction of the information documented over many decades of work toward ending brutality by police in the St. Louis region and beyond.

Note: This slideshow has no audio.

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  • ACLU-MO Records (wua00355), Series 3, Boxes 24–27 contain extensive files on Mattis v. Kiesling, Mattis v. Schnarr, and related pleadings.
  • Ashley Jackson. “Patterns of Historical Police Violence, Race and Concentrated Economic Disadvantage.” Poster. Brown School of Social Work, Washington University (April 2019).
  • Donald Russo. “Mattis v. Schnarr: Deadly Force and Fleeing Felons,” 21 St. Louis U. Law Journal 513 (1977)

If you have a question about this post or other topics related to St. Louis history, I can be reached at or on Twitter: @mrectenwald.