County of Los Angeles v. Mendez

Background

In October 2010, two Los Angeles County deputies searched a backyard shack while looking for a parolee. The deputies entered without a warrant and without announcing themselves. A man inside, Angel Mendez, rose holding a BB gun that looked like a small rifle. The deputies shot him fifteen times; Mendez and his wife were severely injured and Mendez later had his right leg amputated. The couple sued the county and the deputies under the Fourth Amendment for the warrantless entry, the failure to announce, and the use of excessive force.

Reasoning

The central question was whether a separate earlier constitutional violation can make a later use of force unreasonable. The Ninth Circuit applied a “provocation rule,” which treated an otherwise reasonable shooting as unlawful if officers had intentionally or recklessly provoked the confrontation by committing another Fourth Amendment violation. The Supreme Court rejected that rule. It held that the established test for excessive force must stand on its own: if a use of force is objectively reasonable under the familiar balancing test, a prior, separate constitutional violation cannot convert it into an unreasonable seizure.

Real world impact

The decision limits plaintiffs’ ability to convert earlier police mistakes into excessive-force wins when the shooting itself is judged reasonable. At the same time, the Court said victims may still pursue damages for other Fourth Amendment wrongs and left open ordinary tort concepts like proximate cause. The Court vacated the Ninth Circuit’s judgment and sent the case back for further consideration of causation and related questions.

Dissents or concurrances

Justice Gorsuch did not participate. Respondents had argued that courts should consider earlier police misconduct when judging reasonableness, but the Court declined to decide that broader question here.