Falyn Bruce v. Derek Guernsey, 2015 U.S. App. LEXIS 1184

On Sept. 6, 2011 a high-school student, Falyn Bruce (17), was the subject of a tip that she had attempted suicide the prior night; the tip came from her ex-boyfriend and was relayed to school officials and then to police dispatch.
Officer Justin Harris responded, spoke briefly with Bruce at a friend’s house, observed no signs of distress, but kept her outside and detained her for under 37 minutes until a county deputy arrived.
Deputy Derek Guernsey arrived, ordered Bruce (and over her father’s objections) into his patrol car, transported her to St. John’s Hospital, and signed a petition for involuntary admission that included alleged falsehoods (e.g., stating a physician’s exam was attached and that Bruce said she was thinking of suicide).
Bruce sued under 42 U.S.C. § 1983 alleging Fourth Amendment unreasonable seizure against Harris and Guernsey; the district court dismissed for failure to state a claim, finding probable cause/arguable probable cause.
The Seventh Circuit affirmed dismissal as to Harris (brief detention reasonable given the tip) but reversed as to Guernsey, concluding that the record could support a Fourth Amendment violation and that Guernsey was not entitled to qualified immunity at this stage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Harris’s short detention violated the Fourth Amendment	Bruce: detention was unlawful because officer had only an unverified tip and no personal observations of suicidality	Harris: dispatcher told him Bruce was possibly suicidal; brief onsite custody to await county unit was reasonable	Held: Harris’s brief detention (≤37 min) was reasonable; no Fourth Amendment violation
Whether Guernsey lawfully seized and transported Bruce to hospital	Bruce: Guernsey had only the same unverified tip, observed no suicidal behavior, and forced transport and false statements made seizure unreasonable	Guernsey: knowledge that Bruce was possibly suicidal plus contextual facts (away from home, skipping school) supported seizure; later admission shows reasonableness	Held: Reversed dismissal; on Bruce’s version Guernsey’s prolonged seizure and false statements may have been unreasonable — case remanded for further proceedings
Whether Guernsey is entitled to qualified immunity	Bruce: no arguable probable cause given calm demeanor, father’s objections, and lack of corroborating observations; false statements defeat immunity	Guernsey: reasonable officer could have believed probable cause existed based on tip and surrounding facts	Held: At pleading stage Guernsey not entitled to qualified immunity; arguable probable cause lacking on pleaded facts

Santana v. Cook Cnty. Bd. of Review, 679 F.3d 614 (7th Cir. 2012) (standard of review for 12(b)(6) dismissal)
Fitzgerald v. Santoro, 707 F.3d 725 (7th Cir. 2013) (Fourth Amendment governs mental-health seizures)
Chathas v. Smith, 884 F.2d 980 (7th Cir. 1989) (officers need not personally witness behavior to have constitutional probable cause)
McKinney v. George, 726 F.2d 1183 (7th Cir. 1984) (state statutory personal-observation requirement does not control Fourth Amendment analysis)
United States v. Hensley, 469 U.S. 221 (U.S. 1985) (collective knowledge and reliance on other agencies’ information)
Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (false statements in sworn documents can vitiate probable cause)
Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (ex ante objective reasonableness for Fourth Amendment analysis)
Harlow v. Fitzgerald, 457 U.S. 800 (U.S. 1982) (qualified immunity standard)