Crowd-Control Projectiles Face a Legal Test in Los Angeles

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Police officers of the Noblesville, Ind., Police Department's Emergency Response Unit tactically breach rooms and hallways of the Camp Atterbury Joint Maneuver Training Center Live Fire Shoot House in central Indiana, May 13. The shoot house consists of steel walls covered in a form of rubber designed to absorb ricochet bullets, ensuring the safety of those inside. Photo by John Crosby. Source: DVIDS.

A federal civil rights trial scheduled to begin April 7 in the Central District of California will test how far police can go when using kinetic impact projectiles to disperse a crowd. The case, Isaac Castellanos v. City of Los Angeles, arises from the celebration after the Dodgers won the 2020 World Series. 

According to the complaint and the plaintiff’s account, Castellanos was in downtown Los Angeles near the arena district when LAPD officers moved in and fired “less-lethal” rounds, one of which struck him in the eye and left him permanently blind in that eye. The case has been on file in federal court since 2022. 

In an interview with Military.com, Monique Alarcon, a partner at Wisner Baum LLP and counsel for the plaintiff, framed the central dispute as largely factual. She said the crowd at that intersection was peaceful, already dispersing, and received no warning before officers fired. According to her account, Castellanos had turned to pull a friend in the right direction when he was struck. She argued that officers cannot justify force against one group based on unrest elsewhere in the city, emphasizing that each crowd must be assessed on its own conditions.

What the Jury Will Actually Decide

The legal standard comes from the Supreme Court’s Fourth Amendment excessive force decision in Graham v. Connor, which says force must be judged from the perspective of a reasonable officer on the scene, not with hindsight. The analysis turns on the totality of the circumstances, including the severity of the suspected offense, any immediate threat, and resistance or flight. 

Alarcon said that the framework favors her client because he was not committing a crime, was not threatening officers, and was leaving when he was struck. She also said the city has acknowledged in its court filings that no warning was given at that specific intersection, even though officers argue warnings had been issued elsewhere in downtown Los Angeles. That matters because a warning somewhere else in the city is not the same thing as warning the people actually standing in front of the skirmish line. 

The case also includes state law negligence claims, and if the jury finds a constitutional violation, the judge could still have to address qualified immunity for the individual officers. 

U.S. Marines with 3rd Battalion, 2nd Marine Regiment, 24th Marine Expeditionary Unit, conduct crowd control during a simulated riot at an embassy reinforcement exercise as part of the 24th MEU’s certification exercise on Marine Corps Base Camp Lejeune, North Carolina, Feb. 21, 2026. CERTEX is a land-based pre-deployment exercise that enhances the integration and collective capability of the Marine Air-Ground Task Force while providing the 24th MEU with an opportunity to train and execute operations in austere and urban environments. U.S. Marine Corps photo by Lance Cpl. Brian Bolin Jr. Source. DVIDS.

“Less-Lethal” Does Not Always Mean Low-Risk

The phrase “less-lethal” can obscure how destructive these weapons can be. The American Academy of Ophthalmology has warned that rubber bullets and similar projectiles can cause severe eye trauma and blindness. The National Institute of Justice has likewise published research on significant injury risks from kinetic impact projectiles. 

Alarcon made essentially the same point in plain terms: “less lethal is—it’s in the name—still lethal.” Her argument is not that these tools can never be used. In fact, she drew a distinction between targeted uses against a specific dangerous individual and firing non-target-specific rounds into a mixed crowd. She said the real problem in this case was the combination of no warning, no immediate threat from Castellanos, and a tactic that risked injuring compliant people, along with anyone else in the area. 

That distinction tracks LAPD’s own formal guidance. LAPD training materials and later use of force directives describe strict limits on 37mm less-lethal launchers, including crowd-control conditions, range restrictions, and approval requirements. 

What the Case Could Mean Going Forward

The broader importance of this trial is not whether courts will ban less-lethal weapons outright. They almost certainly will not. The more realistic question is whether courts will push departments toward narrower, more disciplined use: clear warnings, visible routes for dispersal, more reliance on formation tactics and targeted arrests, and less willingness to fire area-impact rounds into mixed crowds.

Alarcon said officers should “exhaust your available options” before using these weapons. That is where this case could have its biggest effect. A plaintiff’s verdict would not erase less-lethal tools from policing, but it could make departments more careful about when they deploy them, how they document warnings, and whether they can justify using crowd-control munitions when the crowd is already moving out.

The case also carries broader significance as military forces have increasingly been used in domestic support roles during periods of unrest. In recent years, state governors have activated the National Guard in response to protests across the country, and federal authorities have, at times, considered or used active duty forces in limited capacities under statutes like the Insurrection Act

While those forces operate under different command structures, they remain bound by constitutional constraints when engaging with civilians. That overlap raises practical questions about how crowd-control tactics, particularly the use of less-lethal weapons, are coordinated across agencies and whether differing training standards or rules of engagement could lead to inconsistent or escalatory outcomes. 

As jurisdictions continue to rely on both civilian law enforcement and military support during large-scale events, cases like this one may help define not only police limits, but the broader framework governing force in domestic operations.

That matters beyond Los Angeles. Large gatherings, protests, and spontaneous celebrations are not going away. Neither are police crowd-control missions. This trial will help answer a narrower but important question: when officers choose a tool meant to avoid worse violence, how much constitutional discipline must still come first?

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