City and County of San Francisco v. Sheehan
135 S.Ct. 1765, 191 L. Ed. 2d 856, 2015 U.S. LEXIS 3200 (2015)
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Rule of Law:
A police officer is entitled to qualified immunity from a Fourth Amendment excessive force claim unless the officer violated a statutory or constitutional right that was clearly established at the time of the challenged conduct. A right is only clearly established if existing precedent places the legal question beyond debate, and general principles of reasonableness are insufficient to do so.
Facts:
- Teresa Sheehan, who suffers from a schizoaffective disorder, lived in a group home.
- A social worker, Heath Hodge, became concerned for Sheehan's welfare and entered her private room using a key.
- Sheehan threatened Hodge, stating, "I have a knife, and I'll kill you if I have to," causing him to leave and call the police for assistance in detaining her for psychiatric evaluation.
- Officers Reynolds and Holder arrived and, after announcing themselves, used the social worker's key to enter Sheehan's room.
- Sheehan confronted the officers with a kitchen knife and threatened to kill them.
- The officers retreated into the hallway and closed the door.
- Concerned that Sheehan might gather more weapons or escape, the officers chose to re-enter immediately rather than wait for backup.
- Upon their second entry, Sheehan advanced towards them with the knife; the officers' use of pepper spray was ineffective, leading them to shoot her multiple times.
Procedural Posture:
- Teresa Sheehan sued the City and County of San Francisco and Officers Reynolds and Holder in the U.S. District Court.
- The District Court granted summary judgment in favor of the City and the officers.
- Sheehan, as the appellant, appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit Court of Appeals, finding for Sheehan, vacated the summary judgment in part, holding that a jury could find the officers' decision to re-enter the room violated a clearly established Fourth Amendment right.
- The City and the officers, as petitioners, sought and were granted a writ of certiorari from the Supreme Court of the United States.
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Issue:
Do police officers violate a clearly established Fourth Amendment right when, after being threatened by an armed and mentally ill person in her room, they forcibly re-enter the room rather than attempting to accommodate her disability, thereby entitling them to qualified immunity?
Opinions:
Majority - Justice Alito
No. The officers did not violate a clearly established Fourth Amendment right and are therefore entitled to qualified immunity. Qualified immunity protects government officials unless their conduct violates a statutory or constitutional right that was so clearly established at the time that any reasonable official would have known they were violating it. The Court found that while the officers' initial entry was justified by the emergency aid doctrine and their use of force after the second entry was reasonable given the immediate threat, the crucial question was the constitutionality of the second entry itself. The Court declined to rule on whether the second entry constituted a Fourth Amendment violation but held decisively that no existing precedent clearly established that it was unconstitutional. The cases relied upon by the lower court, such as Graham v. Connor, were too general, and other circuit precedents were factually distinguishable. Because no precedent provided fair notice to the officers that re-entering the room of an armed, threatening, and mentally ill person—instead of waiting or using other de-escalation tactics—violated the Fourth Amendment, they are entitled to qualified immunity.
Concurring in part and dissenting in part - Justice Scalia
The Court should have dismissed both questions as improvidently granted, not just the first one. The petitioners engaged in a 'bait-and-switch' tactic by persuading the Court to grant certiorari on a question involving a circuit split over the ADA's application, only to abandon that argument in their merits briefing. The second question, concerning qualified immunity, is a fact-bound issue that is not independently 'certworthy' and would not have been granted review on its own. By deciding the second question, the Court rewarded the petitioners' tactic. To deter future litigants from 'snookering' the Court into hearing uncertworthy cases, the just course would have been to dismiss the entire case.
Analysis:
This decision significantly strengthens the qualified immunity defense for law enforcement officers, particularly in fast-evolving encounters with mentally ill individuals. It clarifies that to defeat qualified immunity, a plaintiff must point to a precedent with highly similar facts, as broad constitutional principles like 'objective reasonableness' are insufficient to create 'clearly established law.' The ruling underscores the high bar for holding officers liable, emphasizing that courts should not use hindsight to second-guess split-second judgments made in dangerous situations. For future litigation, this case makes it much harder to bring Fourth Amendment claims based on an officer's tactical choices (e.g., confronting versus waiting) unless a nearly identical case has already deemed that specific choice unconstitutional.
