How? Wasn't he knocked out of his shoes/dragged on the side of the car?
As a rule of thumb I've learned to demand bullet holes in the front windshield as a necessary adjunct to 'he done tried to run me over' ~ that way we know the officer was IN FRONT OF THE VEHICLE ~ anything else is strictly supposition, and all too often just pettifoggery designed to trick the unwary. So, no bullet holes in the front, no run down! And that's doubly so when the dude guns down someone in the back seat ~ where whatever it was they were doing they sure weren't operating the motor vehicle.
We pay top dollar taxes around here to train these guys to shoot the right people ~ performance is expected. What they do in Texas is anybody's business of course but in Virginia they generally need to be sure of their target!
You do know that around here we don't need a permit to strapon a holster and walk around with our pearl handles showing ~ right?