Anderson v. Creighton

PETITIONER: Russell Anderson
RESPONDENT: Robert E. Creighton, Jr., et ux., et al.
LOCATION: St. Paul, Minnesota

DOCKET NO.: 85-1520
DECIDED BY: Rehnquist Court (1986-1987)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 483 US 635 (1987)
ARGUED: Feb 23, 1987
DECIDED: Jun 25, 1987
GRANTED: Jun 30, 1986

ADVOCATES:
Andrew J. Pincus - on behalf of the Petitioner
John Patrick Sheehy - on behalf of the Respondent

Facts of the case

On November 11, 1983, FBI Agent Russell Anderson, along with other state and federal officers, conducted a warrantless search of the Creighton family home based on the belief that Vadaain Dixon, a man suspected of robbing a bank earlier that day, was hiding in the house. The Creightons sued Anderson in Minnesota state court and filed a claim for monetary damages under the Fourth Amendment. The suit was removed to federal district court, where Anderson moved for dismissal or summary judgment based on his alleged qualified immunity from civil damages liability. Qualified immunity shields government officials from liability for certain violations of an individual’s constitutional rights. The district court granted summary judgment for Anderson after finding that the search was lawful because Anderson had probable cause.

The U.S. Court of Appeals for the Eighth Circuit reversed and held that the case could not be decided on summary judgment because there were unresolved factual disputes regarding the legality of the search. The Court of Appeals also held that that Anderson did not have qualified immunity because the right he allegedly violated was the well-established Fourth Amendment right to protection from warrantless searches of a home.

Question

Can a federal officer who participated in a search that violated the Fourth Amendment be held personally liable for monetary damages if a reasonable officer would have assumed that the search comported with the Fourth Amendment?

Media for Anderson v. Creighton

Audio Transcription for Oral Argument - February 23, 1987 in Anderson v. Creighton

William H. Rehnquist:

We will hear arguments next in No. 85-1520, Anderson against Creighton.

You may proceed whenever you're ready, Mr. Pincus.

Andrew J. Pincus:

Thank you Mr. Chief Justice, and may it please the Court:

In Harlow v. Fitzgerald, this Court held that government officials sued for constitutional violations are entitled to immunity as long as their conduct was objectively reasonable.

The case presents an important question regarding the application of Harlow, a question that has particularly significant implications for actions against law enforcement officers seeking damages for alleged violations of the Fourth Amendment.

The events at issue in this lawsuit relate to the investigation of a bank robbery that occurred in St. Paul, Minnesota, on November 11, 1983.

Petitioner Russell Anderson was a Special Agent with the Federal Bureau of Investigation, assigned to the Bureau's local field office.

He investigated the robbery by obtaining information from the tellers and other witnesses, and concluded that the robbery had been committed by Vadaain Dixon.

Agent Anderson was familiar with Dixon as a result of his investigations of previous bank robberies that Dixon had committed.

He also knew that Dixon had escaped two days earlier from a halfway house in which he was confined prior to sentencing for some of those previous bank robberies.

Because of what he viewed as Dixon's propensity for violence, Agent Anderson determined that Dixon should be apprehended as soon as possible.

Agent Anderson and several of the local St. Paul police officers went to look for Dixon at the homes of his mother and his grandmother.

Dixon was not found at either of those places.

Based upon information that Dixon's wife had been staying with respondents, who are his sister and brother-in-law, and that a car resembling respondent's car had been used in the bank robbery, the officers then went to respondents' home.

Respondents did not consent to a search of their home, but the officers nonetheless entered and searched the home to look for Vadaain Dixon.

The facts concerning the execution of that search are in dispute, but Vadaain Dixon was not found.

Responients subsequently commenced this action for damages against Agent Anderson and the St. Paul police officers, alleging that the warrantless entry in their home violated the Fourth Amendment.

Agent Anderson moved for summary judgment, and the District Court granted his motion, holding that the entry into the home was lawful because it was justified by probable cause and exigent circumstances.

The Court of Appeals vacated the District Court's judgment but found that factual disputes precluded a determination on summary judgment as to the constitutionality of Agent Anderson's conduct.

The Court of Appeals then turned to consider an issue that was not decided by the District Court, whether Agent Anderson was entitled to immunity under this Court's decision in Harlow v. Fitzgerald.

The Court held that Agent Anderson was not entitled to immunity, because the legal standard governing his conduct, the requirement of probable cause and exigent circumstances to execute the warrantless search, had been clearly established at the time of the challenged search.

And the Court of Appeals remanded the case for a trial concerning the merits of respondents' Fourth Amendment claim.

Now let me stress at the outset the limited question that is before the Court in this case.

We do not seek review of the portion of the Court of Appeals' judgment regarding the merits of respondents' Fourth Amendment claim.

And we do not seek a determination by this Court--

Harry A. Blackmun:

Mr. Pincus, would you repeat that last sentence again?

Andrew J. Pincus:

--Yes, sir, we do not seek a determination in this Court about whether or not the District Court properly granted summary judgment.

We haven't sought... we do not raise that issue in our cert petition.

And so the merits of the substantive question, whether Agent Anderson actually violated the Fourth Amendment, are not before the Court.

And we similarly do not seek a determination by the Court as to whether Agent Anderson is entitled to immunity on the facts of this particular case.