I've had occasion to watch a couple of body cam videos lately where rounds were still being fired at the suspect long after they were down on the ground and not moving for a length of time that I think someone could certainly make a rationale argument that the officer should have assessed that the suspect was no longer an immediate threat and they should have stopped pulling the trigger and sending rounds into the crowded shopping center parking lot.
I think that's the sort of thing an attorney could pounce on and honestly, be Not Wrong.