City and County of San Francisco v. Sheehan

Background

A woman with a schizoaffective disorder living in a group home stopped taking medication and threatened a social worker with a knife. The social worker called police and completed a form seeking temporary detention. Two officers entered her room twice after she slammed the door, she advanced with a knife despite pepper spray, and the officers shot her; she survived and later faced criminal charges that were not retried. She sued the City under the Americans with Disabilities Act (ADA) and the officers individually under 42 U.S.C. § 1983 for Fourth Amendment violations.

Reasoning

The Court dismissed the ADA question as improvidently granted because the parties had not sharply argued whether Title II applies to arrests or whether a public entity can be liable under Title II for arrests. On the officers’ personal liability, the Court applied qualified immunity rules. It concluded that the officers did not violate any clearly established Fourth Amendment right when they reopened the door and used force because the situation was dangerous, the officers reasonably feared immediate harm, and no precedent gave them fair warning that their actions were unconstitutional.

Real world impact

The ruling reverses the Ninth Circuit and shields these officers from personal monetary liability. It leaves open whether and how the ADA applies to arrests, because the Court declined to decide that unresolved statutory question. Lower courts must still consider whether particular precedents clearly establish a constitutional violation before denying qualified immunity.

Dissents or concurrances

Justice Scalia (joined in part by Justice Kagan) would have dismissed both questions as improvidently granted, criticizing the case’s procedural posture and the petitioners’ briefing.