Indiana Code

Ind. Code § 35-41-3-3 (2026)

Use of force relating to arrest or escape

✓ current as of May 2026
Find cases: SyfertCases citing this section JustiaInd. Code CornellLII Search CasesGoogle Scholar

     Sec. 3. (a) The following definitions apply throughout this section:

(1) "Chokehold" means applying pressure to the throat or neck of another person in a manner intended to obstruct the airway of the other person.

(2) "Deadly force" includes a chokehold.

     (b) A person other than a law enforcement officer is justified in using reasonable force against another person to effect an arrest or prevent the other person's escape if:

(1) a felony has been committed; and

(2) there is probable cause to believe the other person committed that felony.

However, such a person is not justified in using deadly force unless that force is justified under section 2 of this chapter.

     (c) A law enforcement officer is justified in using reasonable force if the officer reasonably believes that the force is necessary to enforce a criminal law or to effect a lawful arrest. However, an officer is justified in using deadly force only if the officer:

(1) has probable cause to believe that that deadly force is necessary:

(A) to prevent the commission of a forcible felony; or

(B) to effect an arrest of a person who the officer has probable cause to believe poses a threat of serious bodily injury to the officer or a third person; and

(2) has given a warning, if feasible, to the person against whom the deadly force is to be used.

     (d) A law enforcement officer making an arrest under an invalid warrant is justified in using force as if the warrant was valid, unless the officer knows that the warrant is invalid.

     (e) A law enforcement officer who has an arrested person in custody is justified in using the same force to prevent the escape of the arrested person from custody that the officer would be justified in using if the officer was arresting that person. However, an officer is justified in using deadly force only if the officer:

(1) has probable cause to believe that deadly force is necessary to prevent the escape from custody of a person who the officer has probable cause to believe poses a threat of serious bodily injury to the officer or a third person; and

(2) has given a warning, if feasible, to the person against whom the deadly force is to be used.

     (f) A guard or other official in a penal facility or a law enforcement officer is justified in using reasonable force, including deadly force, if the officer has probable cause to believe that the force is necessary to prevent the escape of a person who is detained in the penal facility.

     (g) Notwithstanding subsection (c), (e), or (f), a guard, penal facility official, or law enforcement officer who is a defendant in a criminal prosecution has the same right as a person who is not a guard, penal facility official, or law enforcement officer to assert self-defense under IC 35-41-3-2.

As added by Acts 1976, P.L.148, SEC.1. Amended by Acts 1977, P.L.340, SEC.9; Acts 1979, P.L.297, SEC.2; P.L.245-1993, SEC.1; P.L.12-2021, SEC.7.

 

Notes of Decisions
Cited in 41 cases (13 in the last 5 years), 1982–2026 · leading case: Jennifer Cox v. Evansville Police Dep't & The City of Evansville Babi Beyer v. The City of Fort Wayne, 107 N.E.3d 453 (Ind. 2018).
Jennifer Cox v. Evansville Police Dep't & The City of Evansville Babi Beyer v. The City of Fort Wayne, 107 N.E.3d 453 (Ind. 2018). · cites it 4× “Cities assign police officers law-enforcement and community-protection duties. Fair , 627 N.”
Tennessee v. Garner, 471 U.S. 1 (1985). · cites it 2× “05 (1983); Idaho Code § 19-610 (1979); Ind. Code § 35-41-3-3 (1982); Kan. Stat. Ann.”
McConnell v. McKillip, 573 F. Supp. 2d 1090 (S.D. Ind. 2008). · cites it 2× “Moreover, Indiana Code § 35-41-3-3 authorizes officers to use reasonable force to effect lawful arrests.”
Wilson v. Isaacs, 929 N.E.2d 200 (Ind. 2010). · cites it 2× “The plaintiffs contend on appeal that the government is not immune from liability for the deputy's conduct because disputed facts exist regarding whether the deputy used unreasonable and excessive force contrary to Indiana Code § 35-41-3-3(b), which provides in relevant part: "A…”
Brown v. State, 830 N.E.2d 956 (Ind. Ct. App. 2005). · cites it 4× “" Ind.Code § 35-41-3-3. In our view, the evidence presented at trial demonstrated that this is precisely what occurred here.”
O'BANNON v. City of Anderson, 733 N.E.2d 1 (Ind. Ct. App. 2000). · cites it 4× “In Indiana, I.C. § 35-41-3-3(b) reflects the same principles and provides in relevant part: (b) A law enforcement officer is justified in using reasonable force if the officer reasonably believes that the force is necessary to effect a lawful arrest.”
Thomas P. Donovan v. Hoosier Park, LLC d/b/a Hoosier Park, Racing & Casino, Centaur, Inc., Hoosier Park, L.P., Centaur Holdings, LLC, & Terrance Sollars, 84 N.E.3d 1198 (Ind. Ct. App. 2017). · cites it 2× “See Ind. Code § 35-41-3-3 (b) (1993) (“A law enforcement officer is justified in using reasonable force if the officer reasonably believes that the force is necessary to effect a lawful arrest.”
Fidler v. City of Indianapolis, 428 F. Supp. 2d 857 (S.D. Ind. 2006). · cites it 2× “Fidler may still pursue his state tort claims against the City of Indianapolis stemming from the defendants’ alleged use of excessive force in apprehending and arresting him.”
Kemezy v. Peters, 622 N.E.2d 1296 (Ind. 1993). · cites it 2× “§ 35-41-3-3 (West 1986). Accordingly, the use of excessive force is not conduct immunized by Section 3(7).”
Est. of Williams v. Indiana State Police, 26 F. Supp. 3d 824 (S.D. Ind. 2014). · cites it 2× “Ind.Code § 35-41-3-3(b). The Court need not repeat the Fourth Amendment reasonableness standard in detail here, as the Court set forth that standard above.”
Marquis Dayvon Brooks v. Anderson Police Dept., City of Anderson, & Chris Barnett, 975 N.E.2d 395 (Ind. Ct. App. 2012). · cites it 4× “” Ind. Code § 35-41-3-3 (b). Any claim that excessive force was used by a police officer when making an arrest is analyzed under the reasonableness standard of the Fourth Amendment to the United States Constitution.”
Tom v. Voida, 654 N.E.2d 776 (Ind. Ct. App. 1995). · cites it 2× “I.C. § 35-41-3-3(b). The facts most favorable to Appellant show that Tom was shot as he was "coming at" Voida a second time with his arms spread out.”
Ind. Code § 35-41-3-3(a): 2 cases
Sports, Inc. v. Gilbert, 431 N.E.2d 534 (Ind. Ct. App. 1982).
Sports Bench, Inc. v. McPherson, 509 N.E.2d 233 (Ind. Ct. App. 1987).
Ind. Code § 35-41-3-3(b): 8 cases
Wilson v. Isaacs, 929 N.E.2d 200 (Ind. 2010). “The plaintiffs contend on appeal that the government is not immune from liability for the deputy's conduct because disputed facts exist regarding whether the deputy used unreasonable and excessive force contrary to Indiana Code § 35-41-3-3(b), which provides in relevant part: "A…”
O'BANNON v. City of Anderson, 733 N.E.2d 1 (Ind. Ct. App. 2000). “In Indiana, I.C. § 35-41-3-3(b) reflects the same principles and provides in relevant part: (b) A law enforcement officer is justified in using reasonable force if the officer reasonably believes that the force is necessary to effect a lawful arrest.”
Fidler v. City of Indianapolis, 428 F. Supp. 2d 857 (S.D. Ind. 2006). “Fidler may still pursue his state tort claims against the City of Indianapolis stemming from the defendants’ alleged use of excessive force in apprehending and arresting him.”
Est. of Williams v. Indiana State Police, 26 F. Supp. 3d 824 (S.D. Ind. 2014). “Ind.Code § 35-41-3-3(b). The Court need not repeat the Fourth Amendment reasonableness standard in detail here, as the Court set forth that standard above.”
Tom v. Voida, 654 N.E.2d 776 (Ind. Ct. App. 1995). “I.C. § 35-41-3-3(b). The facts most favorable to Appellant show that Tom was shot as he was "coming at" Voida a second time with his arms spread out.”
Ind. Code § 35-41-3-3(b)(1)(B): 1 case
Maravilla v. United States, 867 F. Supp. 1363 (N.D. Ind. 1994).
Ind. Code § 35-41-3-3(b)(2): 1 case
Ellis v. City of Indianapolis, 800 F. Supp. 733 (S.D. Ind. 1992).
Ind. Code § 35-41-3-3(c): 4 cases
Brumitt v. Smith (S.D. Ind. 2023).
Manery v. Lee (S.D. Ind. 2024).
CENSKE v. United States (S.D. Ind. 2022).
Ind. Code § 35-41-3-3(d): 1 case
Ellis v. State, 553 N.E.2d 829 (Ind. 1990).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.