Palm Beach County, Fla. officer stops bicyclist; four seconds later, he shoots the cyclist four times at point blank range, rendering him a paraplegic. Jury: Excessive force. District court: Pay him $22 mil. Eleventh Circuit: Vacated. The jury got bad instructions. Dissent: The officer didn’t challenge the instruction the majority seizes on; neither side briefed whether it was incorrect; and it wasn’t.