City and County of San Francisco California et. al v. Sheehan

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Civil Rights § 1983
  • Date Filed: May 18, 2015
  • Case #: 13-1412
  • Judge(s)/Court Below: Alito, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Thomas, Ginsburg, and Sotomayor, JJ., joined. Scalia J., filed an opinion concurring in part and dissenting in part, in which Kagan, J., joined. Breyer, J., took no part in the consideration or decision of the case.
  • Full Text Opinion

Officers are entitled to qualified immunity under 42 U.S.C. § 1983 because there is no clearly established law addressing the issue of necessity to accommodate for mental illness

Petitioners dispatched police officers in response to erratic behavior by Respondent, a mentally ill patient living in a group home. The officers entered Respondent’s room after announcing themselves. Respondent brandished a knife, threatening the officers’ lives. Respondent closed the door when the officers retreated from her room. While waiting for backup, the officers reentered Respondent’s room, and the Respondent charged them with the knife. When pepper-spray failed to subdue Respondent, the officers shot her.

Respondent claimed that Petitioners violated her rights under the Americans with Disabilities Act of 1990 because they failed to accommodate her disability during the arrest. She also sued the police officers in their personal capacity for an alleged violation of her Fourth Amendment rights under 42 U.S.C. § 1983. The district court granted summary judgment for the Petitioners. The Ninth Circuit vacated in part.

The Supreme Court refused to decide the issue of whether any accommodation of an armed and violent individual is reasonable or required under Title II of the ADA. Regarding the issue of the officers’ personal liability under 42 U.S.C. §1983, the Court held that the officers were entitled to qualified immunity because there was no clearly established law addressing the issue of necessity to accommodate for mental illness. The officers had no “fair and clear warning of what the constitution requires.”

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