Phillips said that although the investigation is continuing, no criminal charges are expected against the two men — one a nine-year veteran and the other a three-year veteran.

One bullet hit 27-year-old Lisa K. Tomita Kaina in the head and killed her. A second bullet, Phillips said today, hit a head-rest.

The chief would not identify the officers. He said they are on administrative leave, with pay, and they and their families have been in contact with chaplains and the department’s Critical Incident Stress Management Team.

Questioned on the use of deadly force, Phillips said he would stand by the officers.

"We don’t have to lose an officer before they use force," he said. "They are taught to use force."

Had Kaina lived, she would have been charged with various criminal offenses, including robbery for trying to run down a Hertz car rental employee while stealing the 2004 Cadillac from the company’s Kahului Airport location at 3:44 p.m., he said.

The shooting occurred 11 minutes later.

News of Friday’s fatal police shooting on Maui has stirred unpleasant memories for Ronald Becker, Chaminade University associate professor of criminology and criminal justice.

As a young lawman in Montana in 1975, he pursued a stolen car into a small town and was able to box the vehicle in, much like what police officers did in Pa'ia. Like Friday’s situation, Becker got out of his car with his gun drawn, urging the suspect to stop, and when the driver accelerated toward him, Becker fired two shots.

The difference was that Becker missed. The stunned driver stopped the car, and Becker took him into custody.

To this day, Becker questions whether he really needed to fire his weapon.

"I could have just as easily stepped away from the vehicle. I’ve thought about it many times," he said.

Becker’s shooting was justified under the law. In those days, police officers were allowed to shoot at any fleeing suspect who ignored their pleas to stop.

But no more. A 1985 U.S. Supreme Court ruling created a higher standard for use of deadly force: There must be a belief the suspect will cause serious bodily injury or death to the officer or to others.

"And whenever possible, you have to warn an individual, but that depends on whether time or circumstance allows that," Becker said.

Another Supreme Court ruling in 1989 recognized that many situations may appear to be more dangerous than they actually are.

The court established a subjective standard allowing the police officer to act upon a reasonable belief of what’s occurring rather than what was actually happening.

On Friday night, police said Kaina, 27, was driving a stolen 2004 Cadillac and trying to get away during a pursuit when she was shot and killed by an officer. Police said the woman was hit in the head by a single bullet, fired by an officer whose life was endangered as she reversed in his direction.

Some witnesses said the officer was not in immediate danger as she was boxed in by police units on the sidewalk fronting the Pa'ia branch of Bank of Hawai'i. They said it appeared the officer used excessive force.

Others said he may have saved not only his own life but others at the scene. The driver was ignoring pleas to stop, they said, while continuing to maneuver the Cadillac back and forth in an effort to escape.

If that is true, it may be enough to allow investigators from the Maui Police Department Criminal Investigation Unit and the Maui County Prosecutor’s Office to say the use of deadly force was justified under the law.

In any case, Becker said it’s likely the case will end up in civil court by family members seeking damages for wrongful death or violation of constitutional rights.

Family members of Kaina have said they are considering litigation.

"Even in righteous shootings, families generally sue, and the police are often found to be civilly liable by a sympathetic jury," said Becker, who practiced law in Texas and did stints as a judge and prosecutor. "It’s tough to find an impartial jury that doesn’t come with an emotional package."