County of Los Angeles v. Mendez
137 S. Ct. 1539
| SCOTUS | 2017Background
- Deputies Conley and Pederson, searching for a parolee-at-large at a Lancaster home, entered the backyard without a warrant and without announcing their presence.
- Mendez and Garcia lived in a one-room shack on the property; they were napping when the deputies opened the door and pulled back a blanket covering the entrance.
- Mendez rose holding a BB rifle used for pest control; deputies shouted “Gun!” and fired 15 rounds, severely wounding both occupants; the parolee was not on the property.
- Mendez and Garcia sued under 42 U.S.C. §1983, alleging (1) warrantless entry, (2) failure to knock-and-announce, and (3) excessive force.
- The district court found the shooting reasonable under Graham v. Connor but applied the Ninth Circuit’s “provocation rule” to impose liability for excessive force, awarding significant damages.
- The Ninth Circuit affirmed application of the provocation rule (and an alternative proximate-cause rationale) but granted qualified immunity on the knock-and-announce claim; the Supreme Court granted certiorari.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a separate Fourth Amendment violation can make a later objectively reasonable use of force unconstitutional (the Ninth Circuit’s provocation rule) | The deputies’ warrantless, unannounced entry provoked the shooting; that prior violation can render an otherwise reasonable use of force unlawful | The Graham framework controls excessive-force claims; a separate constitutional violation cannot convert a reasonable seizure into an unreasonable one | Rejected the provocation rule: a later reasonable use of force cannot be transformed into an unreasonable seizure by reference to a distinct Fourth Amendment violation |
| Whether the Ninth Circuit’s limiting criteria for the provocation rule (causal link and intentional/reckless conduct) cure its defects | Those limits sufficiently narrow the rule to avoid overreach | The limits are vague, inject subjective intent into an otherwise objective Graham inquiry, and do not fix the rule’s core problem | The limitations do not salvage the provocation rule; it remains incompatible with Graham’s exclusive framework |
| Whether plaintiffs can recover for harms proximately caused by an antecedent Fourth Amendment violation if excessive-force claim fails | Plaintiffs seek recovery for harms flowing from the warrantless entry even if force was reasonable | Defendants note qualified-immunity limits and argue claims must be analyzed under conventional proximate-cause/tort principles | Plaintiffs may recover damages proximately caused by a Fourth Amendment violation under ordinary tort/proximate-cause principles (subject to qualified immunity); no need for provocation rule |
| Whether the Ninth Circuit’s alternative proximate-cause holding properly connected the warrantless entry to the shooting injuries | The entry made it foreseeable that an unannounced intrusion would cause violence, supporting liability | The Ninth Circuit conflated failure-to-knock risks with the warrantless-entry claim and failed to analyze foreseeable risk from the entry itself | Vacated and remanded: the Ninth Circuit should reassess proximate cause as to the warrantless entry (the prior analysis was tainted by conflating distinct claims) |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (reasonableness of force judged by objective totality-of-circumstances test)
- Tennessee v. Garner, 471 U.S. 1 (Fourth Amendment balancing framework for seizures)
- Saucier v. Katz, 533 U.S. 194 (excessive-force reasonableness judged by information available to officers at the time)
- Whren v. United States, 517 U.S. 806 (reasonableness analysis is objective; subjective intent ordinarily irrelevant)
- Heck v. Humphrey, 512 U.S. 477 (§1983 damages governed by tort principles, including proximate causation)
- Paroline v. United States, 572 U.S. 434 (proximate-cause principles require a direct relation between conduct and injury)