Not really. Son of the janitor where my wife worked was shot in the back multiple times and died while fleeing a traffic stop (turns out he had some weed on him) and he was only a passenger. Was ruled a good shoot BECAUSE nobody was there with a video camera to show the truth.
Someone CAN be shot in the back and still be a valid shot, particularly in a car that is fleeing and endangering others. But by itself, bullet holes in the back are frowned upon...