Carissa Oien v. County of San Bernardino, 680 F. App'x 530

Officers responded to a report by Mary Walker that her son, Peter Oien, had stabbed himself multiple times in the chest with a steak knife and was under the influence of drugs.
Officers announced themselves and attempted to communicate with Oien; they heard faint, muffled noises but did not get a clear response.
Officers entered Walker’s residence without a warrant, guns drawn, to search for and render aid to Oien; Oien then rushed at officers holding knives and was shot.
Carissa and E.O. Oien sued federal claims alleging Fourth Amendment unlawful entry/search and Fourteenth Amendment substantive due process violation (unwarranted interference with parent-child relationship) based on the shooting; the district court granted summary judgment for defendants and declined supplemental jurisdiction over state-law claims.
The Ninth Circuit reviewed whether the emergency-aid exception justified warrantless entry and whether the officers’ use of deadly force "shocked the conscience." The panel affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of warrantless entry under Fourth Amendment	Walker’s report was unreliable; entry violated Peter’s privacy rights	Entry was justified by emergency-aid exception given report of self-inflicted stab wounds and signs of distress	Entry reasonable: officers had objectively reasonable basis to render emergency aid and acted with reasonable scope/manner
Officers’ weapons drawn during entry	Displaying guns made entry unreasonable and escalated danger	Guns were reasonable given report of violence and possible threat	Reasonable to have weapons drawn under circumstances
Use of deadly force (Fourteenth Amendment substantive due process)	Shooting unlawfully interfered with parent-child relationship; force was conscience-shocking	Officers acted in self-defense against an immediate knife threat; no purpose to harm	Not conscience-shocking; officers had no time to deliberate and acted in self-defense
Supplemental jurisdiction over state-law claims	Federal court should retain jurisdiction over remaining state claims	District court may decline once federal claims dismissed	Affirmed: district court did not abuse discretion in declining supplemental jurisdiction

United States v. Struckman, 603 F.3d 731 (9th Cir. 2010) (Fourth Amendment protects against unreasonable searches and seizures)
Sheehan v. City & Cty. of San Francisco, 743 F.3d 1211 (9th Cir. 2014) (emergency-aid exception permits warrantless entry; scope/manner must be reasonable)
United States v. Snipe, 515 F.3d 947 (9th Cir. 2008) (tests for objectively reasonable basis and scope under emergency-aid exception)
Sandoval v. Las Vegas Metro. Police Dep’t, 756 F.3d 1154 (9th Cir. 2014) (requirement for specific and articulable facts supporting officers’ belief)
Brigham City v. Stuart, 547 U.S. 398 (2006) (warrantless entry allowed to render emergency assistance or prevent imminent injury)
Gonzalez v. City of Anaheim, 747 F.3d 789 (9th Cir. 2014) (use-of-force conscience-shocking standard; purpose-to-harm test when no time to deliberate)
Crowe v. Cty. of San Diego, 608 F.3d 406 (9th Cir. 2010) (unwarranted state interference with parent-child relationship violates substantive due process)
Porter v. Osborn, 546 F.3d 1131 (9th Cir. 2008) (discussing conscience-shocking standard for excessive force)
San Pedro Hotel Co. v. City of Los Angeles, 159 F.3d 470 (9th Cir. 1998) (district court discretion to decline supplemental jurisdiction)
United States v. Dugger, 603 F.2d 97 (9th Cir. 1979) (urgent-exigency dissipates when occupant promptly responds and is cooperative)