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Ryburn v. Huff

Summarized by: 

Date Filed: January 23, 2012
Case #: 11-208
Per Curiam
Full Text Opinion: http://www.supremecourt.gov/opinions/11pdf/11-208.pdf

Criminal Procedure: A police officer may enter an individual's residence without violating the 4th Amendment if a reasonable police officer in the same position could have had an objectively reasonable basis for fearing imminent violence.

Officer Ryburn and three additional police officers (“police”) responded to a call from a high school informing them that a student, Vincent Huff, had written a letter threatening to shoot up the school. Huff was not at school and the police went to his home in an attempt to interview him. After knocking multiple times and calling the home telephone with no answer the police called the mother’s cell phone. She answered and informed the police that she was in the home with her son. She emerged with her son and was interviewed briefly by the police. When the police asked if there were guns in the home, Huff’s mother turned and ran into the house without saying a word. The police entered fearing that there were guns and that violence was imminent. No guns were found and the threats were shown to be false. Huff filed suit alleging violation of the Fourth Amendment by entering the home without a search warrant.

The District Court found that the police were entitled to qualified immunity because the totality of circumstances could have led a reasonable police officer to believe that there were weapons in the house and that the family or the police were in danger. The Ninth Circuit reversed holding that the District Court was correct in stating that officers may enter without a warrant if they reasonably believe that entry is necessary to protect themselves or others from serious harm, but concluded that there was no way that a reasonable officer could have come to this conclusion.

The Supreme Court reversed. It reasoned that the Ninth Circuit incorrectly viewed each action in isolation. The Court stated that, “reasonableness must be judged from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight.” Additionally the Court chided the Ninth Circuit for changing key aspects of the District Court’s findings.