HATCHETT, Circuit Judge:
Appellant, Linda Harrell, sued appellees, various Decatur County officials, following the shooting death of her husband. Harrell appeals the district court’s order granting summary judgment in favor of all appellees. Because genuine issues of material fact exist concerning the circumstances of her husband’s death, we reverse the district court’s ruling and remand this case for proceedings consistent with this opinion.
I. FACTS
On the evening of October 27, 1990, Decatur County Sheriffs Department Deputy Bob Morris took Annie Jefferson into custody following a domestic disturbance. While transporting Jefferson to the Decatur County Sheriffs Office, Morris observed an automobile, weaving back and forth across the center line of the highway. After calling the dispatcher, Morris turned on the blue lights of his squad car and the driver, Larry Harrell, pulled his automobile off the highway. After Harrell stopped his automobile, Deputy Morris asked him for his driver’s license. During the ensuing conversation, Morris smelled alcohol in the vehicle and asked Harrell whether he had been drinking. Harrell replied, “I drank two or three beers.”
Based on Harrell’s reply, Morris directed him to leave the automobile to take a field sobriety test. Utilizing a device called an Alcansensor, Morris determined that Harrell was legally intoxicated under Georgia law, and arrested him for driving under the influence. Morris then conducted a pat-down search and placed a handcuff on Harrell’s left wrist. As Morris attempted to place the other portion of the handcuff on Harrell’s right wrist, Harrell attacked Morris. Morris fought back using his flashlight. As the altercation continued, the two men fell to the ground and rolled down an embankment into a ditch. In the ditch, Harrell took Morris’s flashlight and hit him with it several times.
Before leaving the ditch, Harrell searched for Morris’s revolver, asking him, “[wjhere’s your gun?” Although his service revolver was hidden in the small of his back, Morris told Harrell that the revolver was on the hill. When Harrell stood up to leave, Morris attempted to follow him, whereupon Harrell kicked him to the ground, threatening to kill him. Harrell then went up the embankment and entered his automobile from the driver’s side. Moments later Morris climbed part way up the embankment and began shooting at Harrell through the passenger side of the automobile. Morris fired five shots, striking Harrell three times. Harrell died as a result of the gunshot wounds.
From the back seat of the squad car, Annie Jefferson observed the events leading to Harrell’s death. Following the incident, Jefferson gave a statement to the investigator, in which she recalled that immediately after the fight Morris drew his weapon, walked part way up the embankment and shouted, “[h]old it, stop, stop.” After hearing Morris shout, Jefferson observed him shoot his re[1572]*1572volver into the passenger side of Harrell’s automobile. She stated that after being shot, Harrell “fell over towards the passenger side of his ear.” In a deposition given pursuant to this lawsuit, Morris testified that as he approached the automobile, he saw Harrell bent over reaching for something under the passenger seat of the automobile. Morris, however, did not remember giving Harrell any verbal commands and admitted that he never saw a weapon in Harrell’s hand or anything resembling a weapon in the automobile.
At the time Morris killed Harrell, the Decatur County Sheriffs Department’s Standard Operating Procedure Manual contained the following provision regarding the use of weapons:
10. Weapons Safety and Use. No deputy shall draw his revolver from its holster unless under the following circumstances:
a. In participation of self-defense or in defense of another.
b. To stop a known fleeing felon who refuses to stop on verbal command.
c. On the pistol range during scheduled practice.
_ (Emphasis added.)
This policy, adopted in 1980, authorized a deputy sheriff to use deadly force to stop a fleeing felon after the giving of a verbal command. This policy was in effect when Morris killed Harrell. The policy predated the Supreme Court’s decision in Tennessee v. Garner, 471 U.S. 1, 105 S.Ct. 1694, 85 L.Ed.2d 1 (1985), which limited the use of deadly force to stop fleeing felons..
During his deposition, Decatur County Sheriff E.W. Phillips stated that he retracted the pre-Garner policy contained in provision 10(b), through verbal instructions to the deputies. Phillips, however, could not recall when he gave the verbal instructions or which deputies were present. During his deposition, Deputy Morris testified that although he did not recall receiving a verbal instruction from Sheriff Phillips or other supervisory officers in the department retract ing the policy, he knew he could not use deadly force to stop a fleeing felon because he had taken a mandatory state training course covering that topic in July, 1990.
II. PROCEDURAL HISTORY
On October 25, 1991, Linda Harrell, Larry Harrell’s spouse, filed a ten count complaint under 42 U.S.C. §§ 1983, 1985, 1986, and 1988 against Morris, Phillips, Decatur County, and members of the Board of County Commissioners, in their individual and official capacities. In her complaint, Harrell sought compensatory and punitive damages for violations of rights secured under the First, Fourth, Fifth, Sixth, Eighth and Fourteenth Amendments to the United States Constitution, and the laws and Constitution of Georgia.
Following discovery, Phillips and Morris filed motions for summary judgment asserting they were entitled to qualified immunity, in their individual and official capacities, against all claims. Decatur County ánd the commissioners also moved for summary judgment, asserting that under the facts of this case, no municipal liability arises under 42 U.S.C. § 1983. In summary orders issued June 11,1993, the district court granted summary judgment in favor of all the appellees, and dismissed Harrell’s claims. She appeals.
III. CONTENTIONS OF THE PARTIES
Linda Harrell contends that the district court erred in granting summary judgment in favor of Morris and Phillips based on qualified immunity because genuine issues of material fact exist that a jury must resolve. Morris and Phillips contend that the essential facts are not in dispute and that Morris acted reasonably in shooting Harrell because Morris was defending himself. Linda Harrell also contends that the district court erred in granting summary judgment for Morris and Phillips, in their official capacity, because qualified immunity does not apply to official capacity claims. Morris and Phillips contend that they are entitled to qualified immunity in their official capacity because Harrell fails to show that a constitutionally deficient policy or custom played a role in Larry Harrell’s death.
[1573]*1573Linda Harrell also contends that municipal liability exists against Decatur County and the County Commissioners because inadequate training policies and supervision were the moving forces behind the constitutional violations. The County contends that it is not liable because Harrell fails to demonstrate that the alleged constitutional violations arose from a County policy or the County’s failure to supervise the Decatur County Sheriffs Department.
Finally, Harrell contends that the district court erred in dismissing her pendent state claim for nuisance because she stated facts sufficient to withstand a motion for summary judgment. The appellants disagree and assert that Harrell’s nuisance claim, like her remaining federal and state claims, does not state a basis for relief on the facts of this case.
IV. ISSUES
The issues we determine on this appeal are whether the district court erred: (1) in granting summary judgment for Phillips and Morris, individually and in their official capacities based on qualified immunity; (2) in granting summary judgment for Decatur County and the Decatur Board of Commissioners, individually and in their official capacities; and (3) in dismissing Linda Harrell’s remaining constitutional and pendent state claims.
V. DISCUSSION
A. Qualified Immunity
The district court granted summary judgment for Phillips and Morris, in their individual capacities, after determining that they were entitled to qualified immunity. That ruling raises a question of law we review de novo, viewing the facts drawn from the pleadings, affidavits and depositions, in the light most favorable to the appellant. Hardin v. Hayes, 957 F.2d 845, 848 (11th Cir.1992); Swint v. City of Wadley, 5 F.3d 1435, 1439 (11th Cir.1993), modified, 11 F.3d 1030 (11th Cir.1994), petition for cert. filed, 62 U.S.L.W. 3707 (U.S. April 18, 1994) (No. 93-1638). On appeal, we must affirm the district court’s ruling if the public officials establish that they are entitled to qualified immunity and no genuine issues of material fact are disputed. Rich v. Dollar, 841 F.2d 1558, 1562 (11th Cir.1988).
Generally, qualified immunity shields public officials performing discretionary functions from civil liability if “their ponduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S.Ct. 2727, 2738, 73 L.Ed.2d 396 (1982). Once public officials prove that they are acting within the scope of their discretionary authority when the allegedly wrongful acts occurred, the burden shifts to the claimant to demonstrate that the public official being sued violated a clearly established right. Swint, 5 F.3d at 1442. A right is clearly established if its contours are:
sufficiently clear that a reasonable official would understand that what he is doing violates that right. This is not to say that an official action is protected by qualified immunity unless the very action in question has previously been held unlawful, but it is to say that in the light of preexisting law, the unlawfulness must be apparent.
Anderson v. Creighton, 483 U.S. 635, 640, 107 S.Ct. 3034, 3039, 97 L.Ed.2d 523 (1987). Thus, if the law was clearly established, the qualified immunity privilege “ordinarily should fail, because a reasonably competent public official should know the law governing his conduct.” Harlow, 457 U.S. at 818-19, 102 S.Ct. at 2738. Likewise, where genuine issues of material fact exist as to whether the public official actually engaged in conduct that violated clearly established law, summary judgment is inappropriate. Rich, 841 F.2d at 1563 (citing Mitchell v. Forsyth, 472 U.S. 511, 526, 105 S.Ct. 2806, 2815, 86 L.Ed.2d 411 (1985)).
Applying these principles to the facts of this case, we begin our inquiry with a review of the applicable law regarding police officers’ use of excessive force. In 1985, the Supreme Court rendered its decision in Tennessee v. Garner, 471 U.S. 1, 11, 105 S.Ct. 1694, 1701, 85 L.Ed.2d 1 (1985), the seminal case governing the use of force in apprehend[1574]*1574ing fleeing felons. In Gamer, a police officer shot an unarmed juvenile, suspected of burglary, to prevent his escape. In considering the constitutionality of a Tennessee statute permitting the use of all necessary means to effect an arrest of a fleeing felon, the Supreme Court concluded that “there can be no question that apprehension by the use of deadly force is a seizure subject to the reasonableness requirement of the Fourth Amendment.” Gamer, 471 U.S. at 7, 105 S.Ct. at 1699. Then, balancing the state’s interest in apprehending suspected felons against the rights of citizens to be free from unreasonable seizures, the Court held:
[t]he use of deadly force to prevent the escape of all felony suspects, whatever the circumstances, is constitutionally unreasonable. It is not better that all felony suspects die than that they escape. Where the suspect-poses no immediate threat to the officer and no threat to others, the harm resulting from failing to apprehend him does not justify the use of deadly force to do so. It is no doubt unfortunate when a suspect who is in sight escapes, but the fact that the police arrive a little late or are a little slower afoot does not always justify killing the suspect. A police officer may not seize an unarmed, nondangerous suspect by shooting him dead.
Gamer, 471 U.S. at 11, 105 S.Ct. at 1701 (emphasis added).
In explicit terms, Gamer stakes out the bright line necessary for determining whether public officials who shoot a fleeing felon are entitled to qualified immunity. Post v. City of Fort Lauderdale, 7 F.3d 1552, 1557 (1993), modified, 14 F.3d 583 (11th Cir.1994). Because the Supreme Court issued Gamer some five years prior to the events in question here, and its holding unequivocally prohibits the use of deadly force to apprehend a fleeing felon, it is axiomatic that at the time Morris killed Harrell the law was clearly established.
Morris and Phillips do not dispute the fact that at the time of Larry Harrell’s death, clearly established law prohibited the use of deadly force to apprehend a fleeing felon. Likewise, Linda Harrell concedes that deputy Morris was acting within the scope of his discretionary authority when he attempted to arrest her husband following a routine traffic stop. See Rich, 841 F.2d at 1564 (police officer may take all reasonable actions pursuant to the performance of his duties and within the scope of his authority). Because the parties do not contest the legal paradigm underlying the application of qualified immunity, the only remaining issue is whether Linda Harrell has introduced evidence sufficient to create a genuine issue of material fact as to whether the appellants violated her husband’s rights under Garner. Hardin, 957 F.2d at 849.
1. Deputy Morris
The focus of our inquiry into deputy Morris’s assertion of qualified immunity is whether his actions violated clearly established law. Rich, 841 F.2d at 1564. To answer this question we consider the facts drawn from the pleadings, affidavits and depositions, in the light most favorable to Harrell. Hardin, 957 F.2d at 848. After considering the facts, we conclude that genuine issues of material facts are in dispute; consequently, qualified immunity is not appropriate. Rich, 841 F.2d at 1562.
In her complaint, Linda Harrell alleged that at the time Morris killed her husband, he was a fleeing felon with a constitutional right to be free from the use of deadly force. She further alleged that because her husband was a fleeing felon, Morris’s use of deadly force was unreasonable and a violation of her husband’s constitutional rights. Finally, she contends that because her husband was fleeing from the scene of the fight, he posed no threat to Morris.
In contrast, Morris maintains that he acted reasonably under the circumstances because at the time he fired his gun, Harrell appeared to be reaching for a weapon under the seat on the passenger side of the automobile.
Although the parties agree on most of the circumstances surrounding Harrell’s death, at least one material fact remains in dispute: what Larry Harrell was doing in his [1575]*1575automobile at the time Morris shot him.1 Morris contends that as he neared the top of the embankment he “saw Harrell on the driver’s seat of [Harrell’s] automobile ... bent over and appeared to ... be reaching for something under his seat on the passenger side of the car.” Although Morris claims that he believed Harrell was reaching for a gun, he admitted that he did not see a weapon in Harrell’s possession. Likewise, no weapon was found in Harrell’s car.
Morris’s recollection sharply conflicts with the account of eye-witness Annie Jefferson, who provided a written statement of the events in question pursuant to the investigation. In contradicting Morris’s recollection, Jefferson did not recall seeing Harrell lean over into the passenger side of his automobile. To the contrary, Jefferson stated: “The deputy ... shot more than once. I saw Larry [Harrell] fall over toward the passenger side of his car. The deputy was shooting through the passenger side of Larry’s car.”
If Harrell was reaching under his seat, as Morris contends, Morris’s conduct may have been reasonable under the circumstances because he may have reasonably believed that Harrell was searching for a . weapon. Anderson, 483 U.S. at 641, 107 S.Ct. at 3039-40. In such circumstances, Morris may have properly acted in self defense. If, however, Harrell was not reaching under the seat, as Jefferson suggests, but was sitting in the driver’s side of his automobile, Morris lacked the asserted basis for believing his life was being threatened, and Morris’s sole justification for self-defense disappears. Absent a basis for believing his life or Jefferson’s life was in danger, Morris had no reason to shoot at Harrell. Thus, the factual dispute of whether Harrell was leaning over towards the passenger seat of the automobile or simply sitting in the driver’s seat must be resolved before a determination can be made regarding the application of clearly established law.
Because the dispute over Harrell’s position in his automobile prior to his death presents a genuine issue of material faet for a fact-finder, we reverse the district court’s order granting summary judgment for Morris on the basis of qualified immunity. Hardin, 967 F.2d at 849; see McKinney v. Dekalb County, 997 F.2d 1440, 1443 (11th Cir.1993) (summary judgment improper based on qualified immunity where parties dispute facts as to what transpired that leads police officer to shoot victim); Sammons v. Taylor, 967 F.2d 1533, 1539 (11th Cir.1992).
2. Sheriff Phillips
Harrell next challenges the district court’s determination that Sheriff Phillips was entitled to qualifi ed immunity in his individual capacity, contending that Phillips is liable because he was responsible for the supervision and implementation of an unconstitutional policy. Phillips disagrees and contends that he is entitled to qualified immunity because Harrell’s “claim against him is a purely derivative one,” and that “there can be no claim against [him] based on a theory of respondeat superior.”
Although Phillips correctly notes that supervisors “cannot be held liable for the acts of employees solely on the basis of responde-at superior,” Fundiller v. City of Cooper City, 777 F.2d 1436, 1443 (11th Cir.1985), “personal participation is not the sine qua non ” for a supervisor to be held liable under § 1983. Swint, 5 F.3d at 1446. Rather, “[personal participation ... is only one of several ways to establish the requisite causal connection.” Swint, 5 F.3d at 1446 (quoting Zatler v. Wainwright, 802 F.2d 397, 401 (11th Cir.1986). The inquiry into causation is a directed one which focuses on the particular duties and responsibilities of the individu[1576]*1576al appellees whose acts or omissions are the alleged cause of the constitutional violation, and liability may be imposed due to an improper policy or from the absence of a policy. See Swint, 5 F.3d at 1446; Monell v. Dep’t of Social Services, 436 U.S. 658, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978) (liability may be predicated upon a showing that an employee’s action implements a policy the body’s officers officially adopted and promulgated). See also Post, 7 F.3d at 1560-61; Rivas v. Freeman, 940 F.2d 1491, 1495 (11th Cir.1991); Brown v. Crawford, 906 F.2d 667, 671 (11th Cir.1990), cert. denied, 500 U.S. 933, 111 S.Ct. 2056, 114 L.Ed.2d 461 (1991); Fundiller, 777 F.2d at 1443.
In her complaint £nd subsequent pleadings, Harrell has alleged that Sheriff Phillips maintained a policy authorizing the use of unreasonable force to apprehend criminal suspects, and that as the elected sheriff of Decatur County, Phillips “had the authority to make policy decisions and to decide what policies were applicable to his deputies.” She further contends that evidence in the record supports the inference that deputy Morris used unreasonable force in this case pursuant to a particular departmental policy.
The policy at issue appears in the department’s Standard Operating Manual, provided to each deputy in the department. Adopted in March, 1980, five years prior to the Supreme Court’s decision in Tennessee v. Garner, the policy permits deputies to use their weapons, “[t]o stop a known fleeing felon who refuses to stop on verbal command.” Because the policy permits deputies to use their weapons to stop a fleeing felon, it violates clearly established law. Garner, 471 U.S. at 11, 105 S.Ct. at 1701 (“[t]he use of deadly force to prevent the escape of all felony suspects, whatever the circumstances, is constitutionally unreasonable”). Phillips, who has been Sheriff of Decatur County since approximately 1969, was responsible for the adoption and promulgation of the pre-Garner policy. He is also responsible for revising outdated departmental policies.
Phillips concedes that the 1980 policy violates Gamer and that as Sheriff it was his responsibility to correct the policy in light of Gamer. • He claims, however, that even though he never formally amended the written policy, he verbally instructed the deputies that they could no longer use deadly force to apprehend fleeing felons. Phillips does not remember instructing deputy Morris of the change in the policy, and Morris does not remember receiving such a verbal instruction from Phillips. Even so, Morris maintains that he knew deadly force could only be used in self-defense or in the defense of others because he had previously enrolled in a mandatory training course where the change in the law was discussed.
Harrell's allegations and the facts surrounding her husband's death permit the reasonable inference that deputy Morris used deadly force against her husband pursuant to a pre-Garner policy Sheriff Phillips promulgated and maintained. Whether Morris actually acted pursuant to the pre-Garner policy when he shot Harrell, however, is a disputed question of material fact that cannot be answered without resolving the factual disputes surrounding Harrell's death or evaluating the credibility of the parties' witnesses. Because a genuine issue of material fact exists as to Harrell's claims against Sheriff Phillips, the district court erred in granting his motion for summary judgment based upon qualified immunity. Fundiller, 777 F.2d at 1443.
B. Official Capacity
In granting summary judgment for deputy Morris and Sheriff Phillips, the district court apparently concluded that the doctrine of qualified immunity protected them from liability in both their individual and official capacities. That conclusion is wrong. It is well-settled that qualified immunity only protects public officials from lawsuits brought against them in their individual capacity. Rivas, 940 F.2d at 1494-95 (citing Harlow, 457 U.S. at 815, 102 S.Ct. at 2736-37). Because qualified immunity does not shield public officials from civil damages in their official capacities, the district court erred in granting summary judgment, based on qualified immunity, for Morris and Phillips in their official capacities. We therefore, reverse the district court order granting [1577]*1577summary judgment in favor of Morris and Phillips in their official capacities.
C. Harrell’s Claims against the County
In her complaint Harrell alleged claims against Decatur County and the Decatur County Commissioners, in their individual capacities. In moving for summary judgment, the County and the Commissioners asserted that: “[t]here is no genuine issue as to any material fact, and these defendants are entitled to judgment in their favor as a matter of law as to any alleged federal claims.” In granting the motion, the district court stated:
Upon a review of this matter the Court finds that while there is some controversy concerning some incidental details, there is no controversy concerning the facts which are material to a resolution of this matter and determines that the Defendant’s motion for summary judgment and the motion to .dismiss ... should be sustained for the reasons asserted in the motions and as elaborated in the brief filed in support thereof.
The district court provided no further analysis or explanation for its decision to grant summary judgment in favor of the County and the Commissioners.
As previously stated, the district court erred in granting summary judgment for Morris and Phillips because genuine issues of material fact exist which are necessary for the resolution of this dispute. Whether the district court’s decision hinged upon a finding that Larry Harrell’s constitutional rights were not violated or upon independent grounds is not apparent from its cursory opinion. The district court failed to discuss the extent of the County’s involvement in the specific policies or departmental supervision which potentially led to Deputy Morris’s actions. We, therefore, cannot conclude from the district court’s opinion that the County was not sufficiently involved to relieve it from liability. Because we reject the district court’s conclusion that no constitutional violation occurred and its order provides no further guidance for its decision, we reverse the order granting summary judgment with respect to the County and the County Commissioners and remand this ease for further proceedings consistent with this decision.
D. Harrell’s remaining claims
In granting summary judgment for all the appellees, the district court dismissed each of Harrell’s claims. Thus, in addition to dismissing her claims under the Fourth and Fourteenth Amendment, the district court also dismissed Harrell’s claims based on the First, Fifth, Sixth and Eighth amendments to the United States Constitution, and her pendent state claims for nuisance and negligence. After reviewing the record and applicable law, we conclude that Harrell’s remaining constitutional claims and her pendent state law claims lack merit, and the district court properly dismissed them. In any event, Harrell failed to challenged the district court’s dismissal of her constitutional claims and the state negligence claim on appeal, and we consider them abandoned. American Key Corp. v. Cole Nat’l Corp., 762 F.2d 1569, 1579 (11th Cir.1985). See also Harris v. Plastics Mfg. Co., 617 F.2d 438, 440 (5th Cir.1980) (failure to discuss an issue in argument portion of brief results in abandonment of issue on appeal).
CONCLUSION
Based on the facts of this case, we hold that issues of material fact exist regarding the circumstances and cause of decedent Larry Harrell’s death, and thus, the district court erred in granting summary judgment in favor of appellants, deputy Morris and Sheriff Phillips. Because genuine issues of material fact exist and the district court provided no analysis regarding its dismissal of the claims against the County appellees, we reverse its decision with respect to Decatur County and the County Commissioners and remand for proceedings consistent with this opinion.
REVERSED and REMANDED for further proceedings.