A protester was shot in the forehead with a kinetic impact projectile by a deputy US Marshal outside the federal courthouse in Portland, Oregon. The victim, featured in PHR's earlier study 'Shot in the Head,' filed suit under the Federal Tort Claims Act for negligence, battery, and intentional infliction of emotional distress. The case, Labella v. United States, settled out of court with the Department of Justice. PHR recommended that all kinetic impact projectiles be phased out of crowd-control arsenals based on over a decade of research showing there is no appropriate role for them in protest policing.