Just over two years ago, in 2015, the U.S. Supreme Court’s decision in City & County of San Francisco, California v. Sheehan portended a potential shift in the court’s view on police use of force. Many police legal advisors read the decision as a signal of the court’s increasing awareness of the tension between traditional doctrines governing police use of force and the circumstances where law enforcement officers are asked to confront persons who are emotionally disturbed, have a mental illness, or present some threat, but who are not directly involved in a crime. Hill v. Miracle is the latest evidence of the courts’ evolving attitude on this issue.2 Two cases, in particular, laid the foundation for the 6th Circuit’s decision in Hill.