City and County of San Francisco v. Sheehan
The Supreme Court ruled that two San Francisco police officers could not be personally sued for shooting a mentally ill woman who threatened them with a knife, because no clear prior court ruling told them that reentering her room instead of accommodating her disability would violate the Constitution.
The Court also dropped a separate question about whether disability law requires police to accommodate armed and violent suspects during an arrest, because the city had changed its legal argument partway through the case and the issue hadn't been fully argued below.
How it got here: A trial court granted summary judgment for the officers and city; the Ninth Circuit partly reversed, and the city and officers asked the Supreme Court to review two questions.
The Case in Depth
What happened
Teresa Sheehan, who suffered from a mental illness, threatened to kill her social worker and grabbed a knife when two San Francisco police officers first entered her room to escort her to treatment. After retreating, the officers reentered without considering accommodations for her disability, and after pepper spray failed, they shot her multiple times. She sued the city under disability law and sued the officers personally for violating her Fourth Amendment rights.
The question before the Court
When police officers forcibly reentered the room of an armed, mentally ill woman who had threatened them, could they be personally sued for violating her Fourth Amendment rights?
The Court's answer
No — the officers could not be held personally liable, because they are protected by qualified immunity, a legal shield that protects officials unless they clearly violated rights that were already firmly established by prior court rulings. The Court found that no earlier case had made clear that reentering Sheehan's room, rather than trying to accommodate her mental illness, would violate the Fourth Amendment given the danger she posed.
The Court did not decide whether reentering actually violated the Constitution — it only decided that any such right was not clearly established at the time, which is enough on its own to grant immunity. The Court separately dropped the disability-law question about accommodating armed suspects during arrests, because the city had switched its legal argument and the issue was never properly argued below.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Police officers responding to mental-health crises involving weapons get continued legal protection from personal lawsuits unless a prior court decision clearly barred their specific actions. The decision leaves unresolved how disability law applies to arrests, so cities and disability advocates still lack a definitive answer on when officers must accommodate a suspect's mental illness during a dangerous confrontation.
What changes now
The case returns to the lower courts, but the Fourth Amendment claims against the individual officers are over — they cannot be held personally liable. The city may still face liability under disability law, since the Court left standing the possibility that a jury could find the city should have accommodated Sheehan; that determination was not resolved and awaits further proceedings on remand. The broader disability-law question about arrests remains undecided nationally.
What this does not decide
The Court did not decide whether the officers actually violated the Fourth Amendment, only that any such right was not clearly established. It also did not decide whether the Americans with Disabilities Act applies to arrests generally, or whether cities can be sued for money damages under that law for how their officers conduct arrests.
Concurrences and dissents
Dissent in part — Justice Scalia
Justice Scalia agreed the disability-law question should be dismissed as improvidently granted, but argued the Court should have dismissed the qualified-immunity question too. He accused the city of using a bait-and-switch tactic, presenting a circuit-split argument to get the case heard and then abandoning it, and argued the Court should not reward that strategy by deciding the only remaining, less significant question.
How the Court got there
The legal reasoning, step by step
- Qualified immunity shields government officials from personal liability unless they violated a right that was 'clearly established' — meaning existing court decisions had already put the constitutional question beyond debate, giving officials room for reasonable mistakes.
- The Court found the officers did not violate the Constitution when they first opened Sheehan's door, since officers may enter a home without a warrant to prevent imminent harm to an occupant or others, and Sheehan had just threatened to kill people while holding a knife.
- The Court also found that, absent her disability, the second entry and the officers' use of force afterward would have been reasonable under the Fourth Amendment's general reasonableness standard, given the ongoing danger and the need to act quickly.
- That left only the narrower question of whether declining to accommodate Sheehan's mental illness before reentering violated a clearly established right. The Court examined the cases the Ninth Circuit relied on — Graham v. Connor, Deorle v. Rutherford, and Alexander v. City and County of San Francisco — and found each involved materially different, far less dangerous facts.
- Because no prior decision addressed a situation like this one — an armed, violent, mentally ill person who had already threatened officers — the Court concluded there was no 'clearly established' rule the officers could have known they were violating.
- The Court also held that evidence the officers deviated from their training did not defeat immunity, since a reasonable officer could still have believed the conduct was justified even if it fell short of best practices.