Copyright © 2021 Katherine Mims Crocker.
 Taylor v. Riojas, 141 S. Ct. 52 (2020) (per curiam).
 McCoy v. Alamu, 141 S. Ct. 1364 (2021) (mem.).
 See Madeleine Carlisle, The Debate over Qualified Immunity Is at the Heart of Police Reform. Here’s What to Know, Time (June 3, 2021, 6:35 PM), https://time.com/6061624/what-is-qualified-immunity/?s=09 [https://perma.cc/R9Y8-WJ46].
 Harlow v. Fitzgerald, 457 U.S. 800 (1982).
 Id. at 817–18.
 Id. at 802 (identifying the defendants as “senior White House aides to former President Richard M. Nixon”).
 See Katherine Mims Crocker, Qualified Immunity and Constitutional Structure, 117 Mich. L. Rev. 1405, 1432–33 (2019).
 See id. at 1414.
 Taylor v. Riojas, 141 S. Ct. 52, 53 (2020) (per curiam).
 Id. (quoting Taylor v. Stevens, 946 F.3d 211, 218 (5th Cir. 2019)).
 See id.; id. at 54 (Alito, J., concurring in the judgment).
 Taylor, 946 F.3d at 222 (quoting Hope v. Pelzer, 536 U.S. 730, 741 (2002)).
 See Taylor, 141 S. Ct. at 54; Stephen M. Shapiro, Kenneth S. Geller, Timothy S. Bishop, Edward A. Hartnett & Dan Himmelfarb, Supreme Court Practice 5-36 (11th ed. 2019) (“This kind of reversal order usually reflects the feeling of a majority of the Court that the lower court result is so clearly erroneous, particularly if there is a controlling Supreme Court precedent to the contrary, that full briefing and argument would be a waste of time.”); id. at 5-37 (characterizing some summary vacaturs in the same manner as summary reversals).
 See Groh v. Ramirez, 540 U.S. 551, 564 (2004).
 E.g., Stanton v. Sims, 571 U.S. 3, 6 (2013) (per curiam) (quoting Ashcroft v. Al-Kidd, 563 U.S. 731, 743 (2011)).
 Safford Unified Sch. Dist. #1 v. Redding, 557 U.S. 364 (2009).
 Id. at 368–69, 375–76. The Court explained that two school officials told the girl “to remove her clothes down to her underwear, and then ‘pull out’ her bra and the elastic band on her underpants.” Id. at 374. The Court said that while “[t]he exact label for this” conduct was “not important,” a “strip search” was “a fair way to speak of it.” Id.
 Kisela v. Hughes, 138 S. Ct. 1148 (2018) (per curiam).
 Id. at 1150–52. The officer had “arrived on the scene after hearing a police radio report that a woman was engaging in erratic behavior with a knife.” Id. at 1150. At the time the officer fired, the woman “had taken steps toward another woman standing nearby, and had refused to drop the knife after at least two commands to do so.” Id. The dissent argued, however, that “[t]he record, properly construed at this stage,” indicated that “at the time of the shooting,” the woman “stood stationary about six feet away” from the other woman and “appeared ‘composed and content.’” Id. at 1155 (Sotomayor, J., dissenting) (quoting the record).
 Tolan v. Cotton, 572 U.S. 650 (2014) (per curiam).
 Id. at 651. The plaintiff, Robbie Tolan, has done remarkable work recounting his story about surviving a police shooting set in motion by a botched license-plate lookup. See Barry Svrluga, The Black Baseball Prospect, the Police Shooting and the Club He Never Wanted To Join, Wash. Post. (Dec. 31, 2020, 4:00 AM), https://www.washingtonpost.com/sports/2020/12/31/robbie-tolan-police-shooting [https://perma.cc/CN7Z-JWBJ].
 Sause v. Bauer, 138 S. Ct. 2561 (2018) (per curiam).
 Id. at 2563.
 Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982).
 Taylor v. Riojas, 141 S. Ct. 52, 53 (2020) (per curiam) (quoting Brosseau v. Haugen, 543 U.S. 194, 198 (2004) (per curiam)).
 Petition for Writ of Certiorari at 4–5, McCoy v. Alamu, 141 S. Ct. 1364 (2021) (mem.) (No. 20-31) (quoting McCoy v. Alamu, 950 F.3d 226, 229 (5th Cir. 2020)), https://www.supremecourt.gov/DocketPDF/20/20-31/147498/20200710160817184_McCoy%20Cert%20Petition%20to%20File.pdf [https://perma.cc/28QM-M3US]. More specifically, McCoy suggested that the guard was upset with another prisoner who threw water and that the guard took his anger out on McCoy after the other prisoner blocked his own cell from the spray. Id. at 4.
 Id. at 5.
 McCoy, 950 F.3d at 232–33.
 Id. at 233.
 McCoy, 141 S. Ct. at 1364.
 See Shapiro, Geller, Bishop, Hartnett & Himmelfarb, supra note 14, at 4-21 (explaining that a GVR may be used where “[a] court of appeals decision predates [a] conflicting Supreme Court decision” to allow the lower court to reconsider the matter “in the light of the recent decision”); see also Lawrence ex rel. Lawrence v. Chater, 516 U.S. 163, 167 (1996) (per curiam) (explaining that a GVR may be used “[w]here intervening developments . . . reveal a reasonable probability that the decision below rests upon a premise that the lower court would reject if given the opportunity for further consideration, and where it appears that such a redetermination may determine the ultimate outcome of the litigation”); Henry v. City of Rock Hill, 376 U.S. 776, 777 (1964) (per curiam) (explaining that a GVR “indicate[s] that [the Court] found [its intervening decision] sufficiently analogous and, perhaps, decisive to compel re-examination of the case”).
 Colin Miller, Essay, The End of Comparative Qualified Immunity, 99 Tex. L. Rev. Online 217, 224 (2021) [hereinafter Miller, Comparative Qualified Immunity] (contending in particular that “comparative qualified immunity”—through which “government officials who violated plaintiffs’ constitutional rights immunized themselves from liability by citing to cases in which similar, less egregious conduct was deemed constitutional”—“might have met its end”); see also Anya Bidwell & Patrick Jaicomo, Opinion, Lower Courts Take Notice: The Supreme Court Is Rethinking Qualified Immunity, USA Today (Mar. 2, 2021, 8:59 AM), https://www.usatoday.com/story/opinion/2021/03/02/supreme-court-might-rethinking-qualified-immunity-column/4576549001 [https://perma.cc/H3HK-DSEW] (stating that “[t]hese are still early days in the reconsideration—if not ultimate rejection—of the court-created doctrine” but that “the Supreme Court may now be entering a new dawn on qualified immunity”); Colin Miller, The Supreme Court Issues a (Possibly) Landmark Ruling on Qualified Immunity, EvidenceProf Blog (Feb. 23, 2021), https://lawprofessors.typepad.com/evidenceprof/2021/02/yesterday-the-united-states-supreme-court-issued-a-summary-disposition-inmccoy-v-alamu-that-could-end-up-being-a-landmark-r.html [https://perma.cc/W5GQ-ER25] (suggesting that Taylor and McCoy amount to “a seismic shift in qualified immunity law that will great [sic] constrict the availability of the qualified immunity test”).
 See, e.g., Karen M. Blum, Section 1983 Litigation: The Maze, the Mud, and the Madness, 23 Wm. & Mary Bill Rts. J. 913, 946–47 (2015); Karen Blum, Erwin Chemerinsky & Martin A. Schwartz, Qualified Immunity Developments: Not Much Hope Left for Plaintiffs, 29 Touro L. Rev. 633, 654, 657 (2013); Stephen R. Reinhardt, The Demise of Habeas Corpus and the Rise of Qualified Immunity: The Court’s Ever Increasing Limitations on the Development and Enforcement of Constitutional Rights and Some Particularly Unfortunate Consequences, 113 Mich. L. Rev. 1219, 1247 (2015).
 Hope v. Pelzer, 536 U.S. 730 (2002).
 Id. at 741.
 Taylor v. Stevens, 946 F.3d 211, 222 (5th Cir. 2019).
 Taylor v. Riojas, 141 S. Ct. 52, 53–54 (2020) (per curiam) (quoting Hope, 536 U.S. at 741); see Erwin Chemerinsky, SCOTUS Hands Down a Rare Civil Rights Victory on Qualified Immunity, ABA J. (Feb. 1, 2021, 9:11 AM), https://www.abajournal.com/columns/article/chemerinsky-scotus-hands-down-a-rare-civil-rights-victory-on-qualified-immunity [https://perma.cc/FYU2-UH7L] (“Taylor v. Riojas is especially important because it reaffirms Hope v. Pelzer and that there does not need to be a case on point for a plaintiff to prevail and overcome qualified immunity.”).
 McCoy v. Alamu, 950 F.3d 226, 232 (5th Cir. 2020) (quoting Mullenix v. Luna, 577 U.S. 7, 12 (2015) (per curiam)).
 Id. at 233 (quoting Morrow v. Meachum, 917 F.3d 870, 876 (5th Cir. 2019)).
 In Taylor, the Court rejected the Fifth Circuit’s reliance on “‘ambiguity in the caselaw’ regarding whether ‘a time period so short [as six days] violated the Constitution.’” 141 S. Ct. at 54 n.2 (quoting Taylor, 946 F.3d at 222). The decision to which the Fifth Circuit pointed, the Court said, “is too dissimilar, in terms of both conditions and duration of confinement, to create any doubt about the obviousness of Taylor’s right.” Id. (citing Davis v. Scott, 157 F.3d 1003, 1004 (5th Cir. 1998)). By ordering reconsideration in light of Taylor, the Court indicated that the Fifth Circuit’s reliance on prior caselaw in McCoy may have likewise been insufficient to support qualified immunity there. See McCoy, 950 F.3d at 233 (stating that “[i]n somewhat related circumstances, we held that spraying a prisoner with a fire extinguisher ‘was a de minimis use of physical force and was not repugnant to the conscience of mankind’” (quoting Jackson v. Culbertson, 984 F.2d 699, 700 (5th Cir. 1993) (per curiam)).
 For an overview of absolute-immunity doctrine and how it differs from qualified-immunity doctrine, see Richard H. Fallon, Jr., John F. Manning, Daniel J. Meltzer & David L. Shapiro, Hart and Wechsler’s the Federal Courts and the Federal System 1038–39, 1043–47 (7th ed. 2015); and see generally Erwin Chemerinsky, Absolute Immunity: General Principles and Recent Developments, 24 Touro L. Rev. 473 (2008).
 Nathaniel Rubin, Taylor v. Riojas: Qualified Immunity in 2020, Ariz. St. L.J. Blog (Feb. 1, 2021), https://arizonastatelawjournal.org/2021/02/01/taylor-v-riojas-qualified-immunity-in-2020/ [https://perma.cc/D3KQ-BW9K]. Relatedly, in an opinion recognizing Taylor, the Seventh Circuit stated that “[d]etermining whether an officer violates clearly established law requires a look at past cases with specificity” but that the “assessment does not require a case with identical factual circumstances, lest qualified immunity become absolute immunity.” Lopez v. Sheriff of Cook Cnty., 993 F.3d 981, 988, 991 (7th Cir. 2021).
 Jessop v. City of Fresno, 936 F.3d 937 (9th Cir. 2019), cert. denied, 140 S. Ct. 2793 (2020) (mem).
 Petition for Writ of Certiorari at 5–7, Jessop v. City of Fresno, 140 S. Ct. 2793 (2020) (mem.) (No. 19-1021), https://www.supremecourt.gov/DocketPDF/19/19-1021/133072/20200214133249205_19-__%20Jessop%20Petition%202.14.2020%20Final.pdf [https://perma.cc/9PWH-YSGL].
 Jessop, 936 F.3d at 939.
 Jessop, 140 S. Ct. at 2793.
 Jay Schweikert, The Supreme Court Won’t Save Us from Qualified Immunity, Cato Inst.: Cato at Liberty (Mar. 3, 2021, 4:58 PM), https://www.cato.org/blog/supreme-court-wont-save-us-qualified-immunity [https://perma.cc/2899-4J2U]; see also Adam Liptak, Cracks in a Legal Shield for Officers’ Misconduct, N.Y. Times: Sidebar (Mar. 25, 2021), https://www.nytimes.com/2021/03/08/us/supreme-court-qualified-immunity.html [https://perma.cc/5TGX-3KJ8] (quoting Professor Alex Reinert as stating that “[t]he Supreme Court remains very committed to qualified immunity being a forceful defense in civil rights cases and certainly in police excessive force cases”).
 See, e.g., William Baude, Foreword: The Supreme Court’s Shadow Docket, 9 N.Y.U. J.L. & Liberty 1, 1 (2015) (coining the term “shadow docket” to describe “a range of orders and summary decisions that defy [the Court’s] normal procedural regularity”); id. at 18 (observing that “the Court could do more to reassure us that” the products of the shadow docket are not “thoughtless or the result of unjustified inconsistency”); Stephen I. Vladeck, Essay, The Solicitor General and the Shadow Docket, 133 Harv. L. Rev. 123, 156–58 (2019) (discussing the shadow docket’s “[m]essiness,” especially in the context of the federal government seeking stays of injunctions).
 Taylor v. Riojas, 141 S. Ct. 52, 54 (2020) (per curiam).
 See Miller, Comparative Qualified Immunity, supra note 34, at 223 (stating that while the conduct alleged in McCoy “was unconstitutional, it would be difficult to characterize it as ‘particularly egregious’ without making a similar finding about most other unconstitutional behavior by government officers who seek qualified immunity”).
 Josh Gerstein, Supreme Court Turns Down Cases on ‘Qualified Immunity’ for Police, Politico (June 15, 2020, 3:08 PM), https://politi.co/2BcpYwm [https://perma.cc/7SW3-F5G3].
 The Court has also denied other petitions seeking to overturn grants of qualified immunity since then. See Hoggard v. Rhodes, 141 S. Ct. 2421 (2021) (mem.), denying cert. to 973 F.3d 868 (8th Cir. 2020); Howse v. Hodous, 141 S. Ct. 1515 (2021) (mem.), denying cert. to 953 F.3d 402 (6th Cir. 2020).
 See Shapiro, Geller, Bishop, Hartnett & Himmelfarb, supra note 14, at 5-42 (stating that “the summary reconsideration order” does not seem to be “the functional equivalent of a summary reversal order” but instead seems to instruct the lower court “to reconsider the entire case in light of the intervening precedent—which may or may not compel a different result”); see also id. at 4-21 through -22 & nn.36–37 (collecting cases).
 McCoy v. Alamu, 842 F. App’x 933, 933 (5th Cir. 2021) (per curiam).
 Indeed, in a recent skirmish over yet another Fifth Circuit case holding that qualified immunity was warranted, Judge Willett argued that the court was not taking Taylor and McCoy seriously enough. See Ramirez v. Guadarrama, 2 F.4th 506, 522–23 (5th Cir. 2021) (Willett, J., dissenting from the denial of reh’g en banc) (arguing that “while these quiet, ‘shadow docket’ actions may not portend a fundamental rethinking of qualified immunity, the Court seems determined to dial back the doctrine’s harshest excesses” and that “the Court is warning us to tread more carefully when reviewing obviously violative conduct”). In Ramirez, police officers allegedly tased Gabriel Eduardo Olivas “[w]hile responding to a 911 call reporting that Olivas was threatening to kill himself and burn down his family’s house” despite the officers knowing that Olivas had doused himself in gasoline and despite another officer’s warning that tasing Olivas would set him on fire. Ramirez v. Guadarrama, 844 F. App’x 710, 711–12 (5th Cir. 2021) (per curiam). The panel explained what happened next: “Olivas was engulfed in flames. The house burned down. Olivas died of his injuries several days later.” Id. at 711. The district court denied the defendants’ motion to dismiss on qualified-immunity grounds; the panel reversed; and the full Fifth Circuit denied rehearing en banc, prompting Judge Willett’s dissent. See Ramirez, 2 F.4th at 516–17 (Willett, J., dissenting from the denial of reh’g en banc).
 See David M. Shapiro & Charles Hogle, The Horror Chamber: Unqualified Impunity in Prison, 93 Notre Dame L. Rev. 2021, 2023 (2018) (claiming that “the present liability regime” for prison officials “borders on de facto absolute immunity”).
 See North Carolina v. N.C. State Conf. of NAACP, 137 S. Ct. 1399, 1400 (2017) (mem.) (Roberts, C.J., respecting the denial of cert.) (“[I]t is important to recall our frequent admonition that ‘[t]he denial of a writ of certiorari imports no expression of opinion upon the merits of the case.’” (quoting United States v. Carver, 260 U.S. 482, 490 (1923))).
 See George F. Will, Opinion, This Doctrine Has Nullified Accountability for Police. The Supreme Court Can Rethink It., Wash. Post (May 13, 2020), https://www.washingtonpost.com/opinions/will-the-supreme-court-rectify-its-qualified-immunity-mistake/2020/05/12/05659d0e-9478-11ea-9f5e-56d8239bf9ad_story.html [https://perma.cc/T6AK-YE5C] (discussing these cases).
 See Alexander A. Reinert, Qualified Immunity on Appeal: An Empirical Assessment 48–50 (Mar. 4, 2021) (unpublished manuscript), https://papers.ssrn.com/abstract=3798024 [https://perma.cc/4SZS-WNMK] (discussing ideology-related implications of an empirical study of appellate decisions about qualified immunity).
 See Taylor v. Riojas, 141 S. Ct. 52, 54 (2020) (per curiam).
 See Hoggard v. Rhodes, 141 S. Ct. 2421, 2421–22 (2021) (mem.) (Thomas, J., respecting the denial of cert.); Baxter v. Bracey, 140 S. Ct. 1862, 1862–65 (2020) (mem.) (Thomas, J., dissenting from the denial of cert.); Ziglar v. Abbasi, 137 S. Ct. 1843, 1869–72 (2017) (Thomas, J., concurring in part and concurring in the judgment).
 Taylor, 141 S. Ct. at 54 (Thomas, J., dissenting).
 Id. at 54–56 (Alito, J., concurring in the judgment).
 McCoy v. Alamu, 141 S. Ct. 1364, 1364 (2021) (mem.).
 Joanna Schwartz, The Supreme Court Is Giving Lower Courts a Subtle Hint To Rein In Police Misconduct, Atlantic (Mar. 4, 2021), https://www.theatlantic.com/ideas/archive/2021/03/the-supreme-courts-message-on-police-misconduct-is-changing/618193 [https://perma.cc/645G-V76V]; see also Billy Binion, A Prison Guard Who Pepper-Sprayed an Inmate Without Provocation Got Qualified Immunity. SCOTUS Disagreed., Reason (Feb. 23, 2021, 12:44 PM), https://reason.com/2021/02/23/supreme-court-qualfied-immunity-prison-guard-5th-circuit-mccoy-alamu [https://perma.cc/7M44-RK2X] (stating that McCoy was “subtle and went unnoticed by just about every major news outlet”).
 See Crocker, supra note 7, at 1458–60 (arguing that “rejecting Harlow-style qualified immunity would seem well warranted,” that stare decisis “‘is not an inexorable command,’ as the Court has made especially clear in the qualified-immunity context,” and that “there are good reasons to think that completely eliminating qualified immunity would not cause the sky to fall” (quoting Pearson v. Callahan, 555 U.S. 223, 233 (2009))).
 See Schweikert, supra note 49 (“At this point, the only realistic prospect of actual qualified immunity reform is from legislatures, not the Supreme Court.”); Ilya Somin, Supreme Court Rejects Qualified Immunity Defense for the First Time in Years, Volokh Conspiracy (Nov. 2, 2021, 10:21 PM), https://reason.com/volokh/2020/11/02/supreme-court-rejects-qualified-immunity-defense-for-the-first-time-in-years [https://perma.cc/7DHH-J72Q] (“History shows that successful movements to strengthen protection for constitutional rights usually combine litigation with political action, as opposed to exclusively relying on one strategy to the exclusion of the other. Hopefully, the cross-ideological movement to end qualified immunity can continue to make progress in the same way.”).
 Katherine Mims Crocker, A Scapegoat Theory of Bivens, 96 Notre Dame L. Rev. 1943, 1963 (2021) (stating that “with respect to qualified immunity,” the Court “casts about for a dizzying array of constitutional, statutory, and other justifications” but that “Justices have occasionally been forthcoming about the subjective nature of their handiwork”).
 Wyatt v. Cole, 504 U.S. 158, 171 (1992) (Kennedy, J., concurring).
 See, e.g., Roger Michalski & Stephen Rushin, Essay, Federal (De)funding of Local Police, 110 Geo. L.J. Online 54, 63 (2021) (stating that “Congress could overrule the qualified immunity doctrine”); Joanna C. Schwartz, Qualified Immunity’s Boldest Lie, 88 U. Chi. L. Rev. 605, 677–78 (2021) (arguing that “[m]ounting evidence of qualified immunity’s failures offers ample justification for Congress or the Supreme Court to abolish qualified immunity” and that “[i]f Congress or the Supreme Court decides to amend qualified immunity instead of ending it, the definition of ‘clearly established law’ should be at the top of the list for adjustment”); see also William Baude, Is Qualified Immunity Unlawful?, 106 Calif. L. Rev. 45, 80–82 (2018) (exploring arguments for and against congressional authority to change qualified-immunity doctrine).
 See Katherine Mims Crocker, Qualified Immunity, Sovereign Immunity, and Systemic Reform, 71 Duke L.J. (forthcoming 2022) (manuscript at 5–7), https://papers.ssrn.com/abstract=3796337 [https://perma.cc/G28U-HKZJ].
 See id. at 16–25.
 See id.
 See id. at 26–35; see generally James E. Pfander, Alexander A. Reinert & Joanna C. Schwartz, The Myth of Personal Liability: Who Pays When Bivens Claims Succeed, 72 Stan. L. Rev. 561 (2020) (studying indemnification in the federal-officer context); Joanna C. Schwartz, Police Indemnification, 89 N.Y.U. L. Rev. 885 (2014) (studying indemnification in the state- and local-officer context).
 See generally Crocker, supra note 73.
 See id. at 44–52; see also Katherine Mims Crocker, Reconsidering Section 1983’s Nonabrogation of Sovereign Immunity, 73 Fla. L. Rev. 523, 585–88 (2021).
 The Reidout: Symone Sanders: Biden Believes ‘Qualified Immunity Needs To Be Reined In,’ at 1:30–48 (MSNBC television broadcast Aug. 26, 2020), https://www.msnbc.com/the-reidout/watch/symone-sanders-biden-believes-qualified-immunity-needs-to-be-reined-in-90698821998 [https://perma.cc/BYT3-FNZ3].
 Scott Shackford, Democratic Party Platform Calls for ‘Reining In’ Qualified Immunity. Why Not Eliminate It?, Reason (Aug. 20, 2020, 2:05 PM), https://reason.com/2020/08/20/democratic-party-platform-calls-for-reining-in-qualified-immunity-why-not-eliminate-it [https://perma.cc/L69C-B3SL].
 Marianne Levine & Nicholas Wu, Bipartisan Police Reform Talks Crumble, Politico (Sept. 22, 2021, 4:08 PM), https://politi.co/3kv8mQE [https://perma.cc/ME3Z-LCCK].
 See George Floyd Justice in Policing Act of 2021, H.R. 1280, 117th Cong. § 102 (2021) (as passed by House, Mar. 3, 2021), https://www.congress.gov/bill/117th-congress/house-bill/1280 [https://perma.cc/5ZMR-VGVF].
 See Seung Min Kim, Annie Linskey & Marianna Sotomayor, Chauvin Verdict Injects a Fresh Jolt of Momentum into Police Overhaul Efforts, Wash. Post (Apr. 21, 2021, 7:58 PM), https://www.washingtonpost.com/politics/chauvin-verdict-police-overhaul/2021/04/21/fa47d65c-a2a0-11eb-85fc-06664ff4489d_story.html [https://perma.cc/9UPH-C5XF] (stating that Senator Tim Scott said “one potential compromise is holding liable police departments, rather than individual officers”); Anya Bidwell, Patrick Jaicomo & Nick Sibilla, Opinion, Hope for Reforming Qualified Immunity? It May Lie in a Compromise Bill, a Leaked Draft Shows, USA Today (July 27, 2021, 4:27 PM), https://www.usatoday.com/story/opinion/2021/06/24/reform-qualified-immunity-hold-federal-officers-accountable/7705663002 [https://perma.cc/5BLL-BUQC] (describing and providing a link to draft legislation).
 Press Release, Joint Economic Committee Democrats, Beyer, Kaine Introduce Legislation to Address the Cost of Police Misconduct to Municipal Governments (Mar. 2, 2021), https://www.jec.senate.gov/public/index.cfm/democrats/2021/3/beyer-kaine-introduce-legislation-to-address-the-cost-of-police-misconduct-to-municipal-governments [https://perma.cc/NAQ5-W3UR]; see Cost of Police Misconduct Act of 2021, S. 540, 117th Cong. (2021), https://www.congress.gov/bill/117th-congress/senate-bill/540 [https://perma.cc/79E8-42FJ]; Cost of Police Misconduct Act of 2021, H.R. 1481, 117th Cong. (2021), https://www.congress.gov/bill/117th-congress/house-bill/1481 [https://perma.cc/2A9K-DXJT].
 See Crocker, supra note 73, at 53–55.