Guan v. City of New York, 37 F.4th 797

APS removed Guan's 21-year-old autistic son from their home and admitted him to Mount Sinai for an emergency psychiatric evaluation.
Guan went to Mount Sinai, was denied access to her son, became distraught, and called 911 multiple times; hospital security twice reported her as trespassing.
Officers Boyle and Larasaavedra twice encountered Guan; hospital staff told officers she was emotionally disturbed and should be seen by a psychiatrist; officers observed her upset and heard allegations she accused staff of kidnapping/abuse.
Officers handcuffed Guan, removed her from Mount Sinai, and transported her to a different hospital for an involuntary psychiatric evaluation; she was released ~3 hours later and never charged with a crime.
The district court granted summary judgment for defendants, concluding probable cause for trespass precluded the mental-health false-arrest claim and, alternatively, that officers had arguable probable cause (qualified immunity).
The Second Circuit held the district court erred in treating criminal probable cause as dispositive for a mental-health seizure claim but affirmed on qualified immunity grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether probable cause to arrest for criminal trespass precludes a false-arrest claim based on an emergency mental-health detention	Guan: No — mental-health seizures require a separate dangerousness showing; different legal standard	Defs: Yes — Devenpeck/Jaegly permit an arrest supported by probable cause for any offense to defeat a false-arrest claim	Court: No — criminal probable cause does not obviate the separate dangerousness inquiry required for mental-health arrests; district court erred
Whether officers are entitled to qualified immunity for the mental-health arrest	Guan: No — officers lacked probable cause and law was clearly established	Defs: Yes — law was not clearly established in 2017 and officers had arguable probable cause	Court: Yes — officers protected: (1) it was not clearly established they could not rely on criminal probable cause without separate dangerousness finding, and (2) arguable probable cause existed given the totality of circumstances

Devenpeck v. Alford, 543 U.S. 146 (2004) (criminal-arrest context: probable cause to arrest for any offense can justify an arrest)
Jaegly v. Couch, 439 F.3d 149 (2d Cir. 2006) (probable cause for any crime defeats a false arrest claim in criminal-arrest cases)
Myers v. Patterson, 819 F.3d 625 (2d Cir. 2016) (mental-health seizures require a showing of dangerousness)
Anthony v. City of New York, 339 F.3d 129 (2d Cir. 2003) (officers need reasonable grounds to believe person is dangerous for mental-health detention)
Green v. City of New York, 465 F.3d 65 (2d Cir. 2006) (dangerousness standard for transport/detention for psychiatric evaluation)
Kerman v. City of New York, 261 F.3d 229 (2d Cir. 2001) (handcuffing/detaining for mental-health reasons implicates dangerousness requirement)
Figueroa v. Mazza, 825 F.3d 89 (2d Cir. 2016) (probable cause is a complete defense to false arrest)
Vitek v. Jones, 445 U.S. 480 (1980) (involuntary commitment produces a massive curtailment of liberty and stigma)
Ziglar v. Abbasi, 137 S. Ct. 1843 (2017) (qualified immunity protects all but the plainly incompetent or those who knowingly violate the law)
Malley v. Briggs, 475 U.S. 335 (1986) (qualified immunity shields reasonable mistakes of law by officers)