Adria Hill v. Orange County Sheriff, 666 F. App'x 836

On June 16, 2011 a violent armed robbery/kidnapping occurred at a mall store; surveillance footage and tips identified Collie P. White as a suspect and an arrest warrant was obtained.
The Orange County Sheriff’s Office obtained phone geolocation (cell ping) data that placed White on Woodman Way; covert officers set up surveillance near 1160 Woodman Way.
Team officers radioed that they observed White near the building and saw him rush into 1160 Woodman Way; Sergeant Stelter then ordered entry to apprehend White.
Corporal Joseph Covelli and other Team officers forcibly entered unit(s) at 1160 Woodman Way around 7:00 PM; Adria Hill’s (an African-American tenant) home was searched though White was not found there.
Hill sued under 42 U.S.C. § 1983 alleging Fourth Amendment (illegal warrantless entry), Fifth/Fourteenth Amendment (due process/equal protection) and supervisory liability claims against Sheriff Demings; the district court granted summary judgment for defendants.
The Eleventh Circuit affirmed: concluded Covelli was entitled to qualified immunity on the Fourth Amendment claim (exigent circumstances could be reasonably believed to exist), Hill failed to raise an equal protection claim, and supervisory liability against Demings failed because no clearly established violation was shown.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourth Amendment: warrantless entry into Hill’s home	Hill: officers had no warrant and White was never in her home, so entry violated her Fourth Amendment rights	Covelli: officers had probable cause to arrest White and objectively reasonable exigent circumstances justified warrantless entry; qualified immunity applies	Affirmed for defendants — qualified immunity for Covelli; exigent circumstances reasonably could be believed to exist
Clearly established law for qualified immunity	Hill: right against this entry was clearly established at the time	Defendants: law did not clearly establish that entry was unlawful under these facts	Affirmed — Hill did not show a clearly established right violated
Equal Protection (Fourteenth Amendment) — racially motivated searches	Hill: officers would not have entered homes of white residents without a warrant; searches were race-motivated	Defendants: entry was motivated by efforts to apprehend suspect, not race	Affirmed — Hill failed to produce sufficient evidence of discriminatory intent
Supervisory liability against Sheriff Demings	Hill: failure to train/supervise caused deputies to violate constitutional rights	Demings: supervisory liability requires an underlying constitutional violation that is clearly established; none shown here	Affirmed — no supervisory liability because no clearly established violation by subordinates

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard) (explains burden on movant at summary judgment)
Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard) (officials protected unless clearly established law prohibited the conduct)
Lee v. Ferraro, 284 F.3d 1188 (11th Cir. 2002) (two-step qualified immunity inquiry and plaintiff’s burden)
Black v. Wigington, 811 F.3d 1259 (11th Cir. 2016) (photo-lineup and tips can establish probable cause for arrest)
Gennusa v. Canova, 748 F.3d 1103 (11th Cir. 2014) (exigent-circumstances analysis requires totality of circumstances)
Minnesota v. Olson, 495 U.S. 91 (Fourth Amendment protections for the home; context for exigent-circumstances exceptions)
Warden v. Hayden, 387 U.S. 294 (exigent circumstances can justify warrantless entry where delay would endanger lives or allow escape)
United States v. Watson, 423 U.S. 411 (probable cause to arrest can be established without a warrant)
Rioux v. City of Atlanta, 520 F.3d 1269 (11th Cir. 2008) (standard of review on summary judgment)
United States v. Young, 909 F.2d 442 (exigent-circumstances evaluation is objective)