City and County of San Francisco v. Sheehan

PETITIONER: City and County of San Francisco, California, et al.
RESPONDENT: Teresa Sheehan
LOCATION: Conrad House

DOCKET NO.: 13-1412
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 575 US (2015)
GRANTED: Nov 25, 2014
ARGUED: Mar 23, 2015
DECIDED: May 18, 2015

ADVOCATES:
Ian H. Gershengorn - for the petitioners
Leonard Feldman - for the respondent
Christine Van Aken - for the petitioners

Facts of the case

Teresa Sheehan suffered from a mental illness and lived in a San Francisco group home. After Sheehan threatened her social worker when he attempted to perform a welfare check, he became concerned that she was a danger to herself or others and summoned the police for help transporting her to a mental health facility for a 72-hour involuntary commitment. When the police officers arrived, they entered Sheehan's room without a warrant to take her into custody. Sheehan grabbed a knife and threatened to kill the officers. They were forced to withdraw outside her room and call for backup, but instead of waiting for the backup to arrive, they drew their weapons and forced their way back into her room. When Sheehan again threatened the officers with a knife, they shot her several times.

Sheehan sued the officers and the city for violations of her Fourth Amendment right to be free from warrantless searches and seizures as well as violations of the Americans with Disabilities Act. The district court granted summary judgment in favor of the defendants, and Sheehan appealed. The U.S. Court of Appeals for the Ninth Circuit held that there were triable issues of material fact regarding whether the officers' second entry into Sheehan's room was reasonable under the circumstances and whether the officers failed to reasonably accommodate Sheehan's disability as required by the Americans with Disabilities Act.

Question

(1) Did the officers violate a clearly established right under the Fourth Amendment when they forced entry into Sheehan’s room the second time?

(2) Does the Americans with Disabilities Act require law enforcement officers to provide accommodations to an armed, violent and mentally ill suspect when attempting to take that suspect into custody?

Media for City and County of San Francisco v. Sheehan

Audio Transcription for Opinion Announcement - May 18, 2015 in City and County of San Francisco v. Sheehan

Samuel A. Alito, Jr.:

The second case is City and County of San Francisco versus Sheehan, number 13-1412.

We granted certiorari in this case to address two questions.

First, whether Title II of the Americans with Disabilities Act requires law enforcement officer to provide accommodations to an armed violent and mentally ill suspect in the course of brining the suspect into custody.

Second question is whether police officers can be personally sued for money damages for failing to accommodate a mental illness in the course of subduing a dangerous person who had threatened to kill them with a knife.

We dismiss the first question as improvidently granted.

As to the second, we hold that because the officers did not violate any clearly established law, they are entitled to qualified immunity.

Respondent Teresa Sheehan lived in a group home for those dealing with mental illness.

After she began acting erratically, a social worker stopped by her room to conduct a welfare check.

Respondent responded violently, reportedly yelling, "I have a knife and I'll kill you if I have to."

Understandably concerned, the social worker contacted the police to assist him in taking Sheehan to a secure facility for temporary evaluation and treatment.

This was authorized under California Law. Sergeant Kimberly Reynolds and Officer Katherine Holder accompanied the social worker to Sheehan's room.

They knocked on her door, announced who they were, and told Sheehan that they wanted to help her.

When she did not respond, they entered her room.

Sheehan again reacted violently and threatened to kill them with a knife.

The officers retreated and Sheehan closed the door.

Concerned about what Sheehan might do, including gathering more weapons, the officers decided to re-enter her room.

They did not stop to consider accommodating her disability.

After they forced open the door, Sheehan again came at them with a knife.

The officers tried to subdue her with pepper spray, but she would not drop the knife.

They then shot Sheehan.

Thankfully, she survived.

Sheehan sued petitioner, San Francisco, for allegedly violating the Americans with Disabilities Act.

She also sued petitioners, Reynolds and Holder, in their personal capacities for allegedly violating the Fourth Amendment.

The District Court granted summary judgment.

It concluded that the ADA does not apply in situations such as this, and that these officers did not violate the constitution.

The Ninth Circuit vacated in part, holding that the ADA does apply and that a jury should decide whether Sheehan's disability was properly accommodated.

The Ninth Circuit also held that although much of what the officers did was lawful, it was unconstitutional to provoke Sheehan's violent reaction by forcibly re-entering her room without an objective need for immediate re-entry.

We granted certiorari to consider both questions.

Unfortunately, San Francisco has not advanced the same argument here that it did in the Ninth Circuit.

When we granted certiorari, we understand -- we understood San Francisco to argue that the ADA does not apply when an officer faces an armed and dangerous person.

Sarah from Law Aspect

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