What is the purpose to harm standard for a police officer to reasonably fire a single shot at a suspect?

"The purpose to harm standard is a subjective standard of culpability." Id. It is well established that a use of force intended to "teach a suspect a lesson" or "get even" meets this standard. Id . at 1141. For example, in A.D. , we affirmed the denial of the defendant officer's motion for judgment as a matter of law in light of evidence that the decedent posed no danger to anyone and repeatedly insulted the officer before the officer shot her twelve times, even though no other officer opened fire and a supervisor had ordered the officer to stop. A.D. , 712 F.3d at 451. We have also reversed a grant of summary judgment where a police officer, who had reasonably fired eighteen shots at a suspect who had just stabbed another officer, walked in a circle around the suspect and then took a running start before stomping on the suspect's head three times. Zion v. County of Orange , 874 F.3d 1072, 1077 (9th Cir. 2017).