In 1995, Officer Ludwig was involved in a case where the Eighth Circuit held that police officers were not entitled to qualified immunity from a claim that they employed excessive force in seizing an individual through the use of deadly force. The case emphasized the need for officers to assess the threat posed by individuals before using deadly force. ([casetext.com](https://casetext.com/case/brown-v-city-of-bloomington?utm_source=openai))

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