Donald Machan v. Shawn Olney, 958 F.3d 1212

Seventh-grade student T.R. told the school principal she had been contemplating suicide for about a month and that seeing guns and knives at home made her want to hurt herself. A body-camera video corroborates this.
Principal Gill-Williams summoned school officer Shawn Olney, who called T.R.’s father, Donald Machan. Machan objected and asked that T.R. be kept at school until he arrived.
Olney nevertheless took T.R. to a nearby hospital for a psychiatric evaluation; hospital staff conducted a mental-health assessment and, over resistance, a routine blood draw (which was negative for drugs).
Machan arrived, renewed his objections, and after discussion hospital staff released T.R. to Machan on condition he take her to a mental-health center; they went there briefly and then home.
Machan sued, alleging Olney violated T.R.’s and his Fourth Amendment and substantive due process rights (including authorizing the blood draw without parental consent); the district court denied Olney qualified immunity.
The Sixth Circuit reviewed the videotape and held Olney had probable cause to detain T.R. for a mental evaluation and was entitled to qualified immunity; it reversed and directed judgment for Olney.

Issue	Machan's Argument	Olney's Argument	Held
Whether taking T.R. to hospital for psychiatric evaluation without Machan's consent violated the Fourth Amendment	Olney lacked probable cause because T.R. did not express an immediate intent to act on suicidal thoughts; Machan objected and asked that T.R. be kept at school	T.R.’s own report of month-long suicidal thoughts and access to weapons gave probable cause to believe she was a danger to herself, authorizing protective seizure	Court: Olney had probable cause; seizure lawful for psychiatric evaluation
Whether authorizing a blood draw without parental consent violated the Fourth Amendment	Blood draw was nonconsensual and required parent permission	Blood draw was part of a reasonable psychiatric evaluation of a potentially suicidal person and thus permissible	Court: Blood draw was permissible as part of the evaluation
Whether Olney’s conduct violated substantive due process (father’s and child’s claims)	Conduct was arbitrary and deprived plaintiffs of rights without justification	No clearly established law showing officer’s conduct was unlawful in this context	Court: No clearly established precedent; Olney entitled to qualified immunity on substantive due process claims

Hayden v. Green, 640 F.3d 150 (6th Cir. 2011) (video evidence can contradict plaintiff’s version of events on summary judgment)
Scott v. Harris, 550 U.S. 372 (2007) (video may control disputed facts where it clearly contradicts plaintiff’s account)
Monday v. Oullette, 118 F.3d 1099 (6th Cir. 1997) (Fourth Amendment requires probable cause that person is dangerous to justify psychiatric seizure)
Ziegler v. Aukerman, 512 F.3d 777 (6th Cir. 2008) (probable cause for mental-health seizure requires substantial chance of dangerous behavior)
Fisher v. Harden, 398 F.3d 837 (6th Cir. 2005) (distinguishing seizures where subject’s appearance and conduct indicate a benign encounter)
Bruce v. Guernsey, 777 F.3d 872 (7th Cir. 2015) (no seizure where student showed no signs of distress)
District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (qualified immunity requires that existing precedent make unlawfulness of conduct apparent to a reasonable officer)