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City & Cty. of S.F. v. Sheehan - 135 S. Ct. 1765 (2015)

Rule:

Public officials are immune from suit under 42 U.S.C.S. § 1983 unless they have violated a statutory or constitutional right that was clearly established at the time of the challenged conduct. An officer cannot be said to have violated a clearly established right unless the right’s contours were sufficiently definite that any reasonable official in his shoes would have understood that he was violating it, meaning that existing precedent placed the statutory or constitutional question beyond debate. This exacting standard gives government officials breathing room to make reasonable but mistaken judgments by protecting all but the plainly incompetent or those who knowingly violate the law.

Facts:

Respondent Sheehan lived in a group home for individuals with mental illness. After Sheehan began acting erratically and threatened to kill her social worker, the City and County of San Francisco (San Francisco) dispatched police officers Reynolds and Holder to help escort Sheehan to a facility for temporary evaluation and treatment. When the officers first entered Sheehan's room, she grabbed a knife and threatened to kill them. They retreated and closed the door. Concerned about what Sheehan might do behind the closed door, and without considering if they could accommodate her disability, the officers reentered her room. Sheehan, knife in hand, again confronted them. After pepper spray proved ineffective, the officers shot Sheehan multiple times. Sheehan survived and later sued petitioner San Francisco for, among other things, violating Title II of the Americans with Disabilities Act of 1990 (ADA) by arresting her without accommodating her disability. She also sued petitioners Reynolds and Holder in their personal capacities under claiming that they violated her Fourth Amendment rights. The District Court granted summary judgment because it concluded that officers making an arrest were not required to determine whether their actions would comply with the ADA before protecting themselves and others, and also that Reynolds and Holder did not violate the Constitution. Vacating in part, the Ninth Circuit held that the ADA applied and that a jury must decide whether San Francisco should have accommodated Sheehan. The court also held that Reynolds and Holder are not entitled to qualified immunity because it is clearly established that, absent an objective need for immediate entry, officers cannot forcibly enter the home of an armed, mentally ill person who has been acting irrationally and has threatened anyone who enters.

Issue:

Were police officers entitled to qualified immunity as to a mentally-ill person's Fourth Amendment claim?

Answer:

Yes.

Conclusion:

The Court held that Police Officers Reynolds and Holder were entitled to qualified immunity as to Sheehan’s  Fourth Amendment claim because the officers' failure to accommodate her illness did not violate clearly established law since competent officers could have believed that the second entry was justified under both continuous search and exigent circumstance rationales.

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