4 INDIANA LAW JOURNAL [Vol. 92:01
teenager being killed by a police officer after having, allegedly, stolen some
cigarillos from a convenience store.
5
It is the cause and consequence of a black man
being choked to death by police for selling loose cigarettes.
6
And the question that
attacking police officers, chanting slogans such as “Killer cops modern lynchers” and “Philly
is Baltimore.” Jon Hurdle & Daniel E. Slotnik, Clashes in Philadelphia as Freddie Gray Protest
Neared Highway, N.Y. TIMES (Apr. 30, 2015),
http://www.nytimes.com/2015/05/01/us/clashes-in-philadelphia-as-freddie-gray-protest-
neared-highway.html [https://perma.cc/6M35-Y5F6]. In New York, protestors marched with
those in solidarity with those in Baltimore; however, two officers were assaulted, and those
arrested were a “reaction to the behavior of the protesters who were blocking avenues and
streets.” Benjamin Mueller & John Surico, Over 140 Arrested as New Yorkers Protest the
Death of Freddie Gray, N.Y. TIMES (Apr. 30, 2015),
http://www.nytimes.com/2015/04/30/nyregion/hundreds-march-in-manhattan-to-protest-the-
death-of-freddie-gray.html [https://perma.cc/V4UX-JUMD].
5. In Ferguson, Missouri, following the death of Michael Brown at the hands of a police
officer, the community was enraged. Protests turned to riots. Almost immediately, the
aftermath of the announcement was violence. President Obama addressed the nation, urging
peace and calm. Most networks carrying the remarks cut to a split screen—showing riots
breaking out in the streets of Ferguson next to the president’s pleas. Dozens of storefronts
were looted, some were burned to the ground. And at least one man, Deandre Joshua, was
killed during the chaos.
Wesley Lowery, It Has Been One Year Since a St. Louis Grand Jury Did Not Charge Darren
Wilson for Michael Brown’s Death, WASH. POST (Nov. 24, 2015),
https://www.washingtonpost.com/news/post-nation/wp/2015/11/24/it-has-been-one-year-
since-a-st-louis-grand-jury-did-not-charge-darren-wilson-for-michael-browns-
death/?utm_term=.e59d7a4aea2e [https://perma.cc/R386-BNLY]. This sentiment was
reiterated by Governor Jay Nixon, but he also conceded that “we will not get the healing that
we all need if the only response from the public is just be quiet.” Brian Resnick, Obama on
Ferguson Police, Protests: ‘We All Need to Hold Ourselves to a High Standard’, THE
ATLANTIC, (Aug. 14, 2014), http://www.theatlantic.com/politics/archive/2014/08/obama-on-
ferguson-police-protests-we-all-need-to-hold-ourselves-to-a-high-standard/453369/
[https://perma.cc/7XAF-FUSD]. The chant “Hands up, don’t shoot,” performed with raised
hands, was repeated as a version of what activists believe were Michael Brown’s last words.
Nicholas D. Mirzoeff, Ferguson Taught Us to Not Look Away, TIME (Aug. 10, 2015),
http://time.com/3991745/ferguson-dont-look-away/.
6. On July 17, 2014, Eric Garner died in Staten Island, New York, after New York City
Police Department officer, Daniel Pantaleo, put him in a chokehold for about fifteen to
nineteen seconds while arresting him. Billy Johnson, Eric Garner’s Death Provokes Outrage
a Year Later, NEWSWEEK (July 17, 2015), http://www.newsweek.com/eric-garners-death-
provokes-outrage-year-later-354989 [https://perma.cc/CF5D-Z2J5]; Abby Ohlheiser, Elahe
Izadi & Cameron Barr, N.Y. Grand Jury Declines to Indict Officer in Death of Eric Garner,
Igniting Protests, WASH. POST (Dec. 3, 2014),
https://www.washingtonpost.com/politics/2014/12/03/8dc55084-7b2b-11e4-84d4-
7c896b90abdc_story.html [https://perma.cc/M6WE-YEE2]. The New York City Medical
Examiner's Office attributed Garner's death to a combination of a chokehold, compression of
his chest, and poor health. Al Baker, J. David Goodman & Benjamin Mueller, Beyond the
Chokehold: The Path to Eric Garner’s Death, N.Y. TIMES (June 14, 2015),
http://www.nytimes.com/2015/06/14/nyregion/eric-garner-police-chokehold-staten-
island.html [https://perma.cc/X5PE-JGX4]. After the Staten Island grand jury failed to indict
Pantaleo on December 3, New York City and San Francisco citizens gathered in protest. Justin