City and County of San Francisco v. Sheehan
135 S. Ct. 1765
| SCOTUS | 2015Background
- Teresa Sheehan, a resident of a group home with schizoaffective disorder, threatened a social worker and was the subject of a 5150 temporary-detention application labeling her a threat to others and gravely disabled.
- San Francisco police Officers Reynolds and Holder, accompanied by the social worker, entered Sheehan’s room once (to welfare-check), retreated when she armed herself with a knife and closed the door, then called for backup.
- Concerned Sheehan might arm herself further or escape, the officers reentered without attempting disability-specific accommodations; pepper spray failed and Holder and Reynolds fired, wounding Sheehan.
- Sheehan sued the City under Title II of the ADA for failure to accommodate during arrest and sued the officers under 42 U.S.C. § 1983 for Fourth Amendment violations; district court granted summary judgment to petitioners.
- The Ninth Circuit reversed in part, holding ADA accommodation could apply and denying qualified immunity for the officers; the Supreme Court granted certiorari on two questions but dismissed the ADA question as improvidently granted and addressed only qualified immunity.
- The Supreme Court held the officers are entitled to qualified immunity because any Fourth Amendment right to a disability-based accommodation in these circumstances was not clearly established.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Title II of the ADA requires law‑enforcement to provide accommodations during arrest of an armed, violent, mentally ill suspect | ADA applies to arrests; failure to accommodate disability during seizure is discrimination | City argued arrestee was not a “qualified individual” because she posed a direct threat (and earlier argued Title II shouldn’t apply to on‑the‑street emergency responses) | Question dismissed as improvidently granted — Court declined to decide whether ADA applies to arrests or vicarious municipal liability under Title II |
| Whether officers violated the Fourth Amendment by reentering instead of accommodating Sheehan’s disability | Reentering provoked confrontation; reasonable accommodation and de‑escalation were feasible and required | Officers reasonably reentered to prevent escape/gathering weapons and to protect safety; exigent circumstances and continuous‑entry doctrine supported reentry | Officers entitled to qualified immunity — no clearly established Fourth Amendment right to require accommodation in these facts |
| Whether the officers’ use of deadly force was excessive once Sheehan advanced with knife | (Plaintiff concedes factual dispute about some details but argues conduct precipitated fatal confrontation) | Use of force was reasonable after nonlethal means failed and Sheehan advanced within a few feet | Use of force found reasonable; not the basis for denying qualified immunity |
| Whether failure to follow departmental training defeats qualified immunity | Expert testimony that officers violated training in dealing with mentally ill should preclude immunity | Deviation from training, without clearly established law showing unconstitutionality, does not defeat qualified immunity | Training evidence insufficient to overcome qualified immunity where no clear constitutional rule existed |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (excessive‑force claims judged by objective reasonableness)
- Brigham City v. Stuart, 547 U.S. 398 (warrantless entry permitted to render emergency assistance or prevent imminent injury)
- Michigan v. Tyler, 436 U.S. 499 (continuous‑search principle for related entries)
- Scott v. Harris, 550 U.S. 372 (use‑of‑force reasonableness standard in high‑risk encounters)
- Saucier v. Katz, 533 U.S. 194 (discussion of qualified immunity framework)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity principles for government officials)
- Deorle v. Rutherford, 272 F.3d 1272 (9th Cir.) (use‑of‑force against an unarmed, emotionally disturbed person)
- Alexander v. City and County of San Francisco, 29 F.3d 1355 (9th Cir.) (provocation and exigency issues in entry leading to use of force)
- Billington v. Smith, 292 F.3d 1177 (9th Cir.) (entries that comply with the Fourth Amendment are not rendered unreasonable by provoked reaction)
- Pennsylvania Dep’t of Corrections v. Yeskey, 524 U.S. 206 (Title II applies to state and local government activities)