A federal judge has cleared the way for a civil trial over the 2022 fatal shooting of Patrick Lyoya, a Black man who was shot in the back of the head by a Michigan police officer.

U.S. District Judge Paul Maloney ruled Thursday that a jury will decide whether former Grand Rapids officer Christopher Schurr violated Lyoya's civil rights under the Fourth Amendment, which protects against unreasonable seizures. Maloney stated that the evidence, when viewed in the light most favorable to Lyoya's family, suggests Schurr shot Lyoya when he posed no threat, was unarmed, and was physically controlled.

"The record suggests that (Schurr) shot a man who posed no threat of violence, held no weapon, and who was under Defendant’s physical control,” Maloney said. “That violates the Fourth Amendment right to be free from unreasonable seizures.”

Schurr, who has maintained he acted in self-defense, claimed Lyoya had gained control of his Taser during a struggle. The shooting occurred in April 2022, following a traffic stop that escalated into a foot chase and a physical confrontation lasting over two minutes. Schurr was on top of Lyoya when the fatal shot was fired. Lyoya was a 26-year-old Congolese immigrant.

Schurr's legal team had argued for immunity in the civil lawsuit, asserting that the use of force was objectively reasonable. However, Judge Maloney indicated that Schurr's account of the Taser incident did not align with video evidence.

"Despite every effort to have this case thrown out, the court ruled that the core of Patrick’s civil rights claims will move forward,” said Ven Johnson, a lawyer representing Lyoya's family.

Schurr, a seven-year veteran of the Grand Rapids Police Department, was fired in 2022 after being charged with second-degree murder. A jury was unable to reach a unanimous verdict on that criminal charge in 2025, leading to the dismissal of the murder case. However, the civil lawsuit proceeds under different legal standards.

A message seeking comment was left for Schurr's attorney.