Huff v. City of Burbank
632 F.3d 539
| 9th Cir. | 2011Background
- Off-duty officers responded to a school threat rumor and investigated at Bellarmine-Jefferson High School.
- They learned Vincent Huff, a student, had been absent and there were rumors of a letter threatening to shoot the school.
- The officers decided to interview the Huff family at their home and approached the residence without a warrant.
- Maria Huff answered a cell call from the officers, then she and Vincent stepped outside; officers sought to enter for questioning.
- Ryburn and Zepeda entered the home with Maria after she returned inside; Munoz and Roberts entered believing consent had been given.
- The officers remained inside for 5–10 minutes, determined the rumor was untrue, and then left; no searches occurred.
- The Huff family sued for Fourth Amendment violations; the district court found exigent circumstances justified entry and denied liability; on appeal, the court reversed in part and affirmed in part.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exigent circumstances justified warrantless entry | Huffs argue no exigency existed | Officers relied on safety concerns indicating exigency | Exigency not proven; warrantless entry invalid regarding four officers |
| Whether officer safety concerns foreclosed Fourth Amendment violation | Zepeda and Ryburn acted to prevent harm | Safety concerns could justify entry | Roberts and Munoz protected by qualified immunity; Ryburn and Zepeda not entitled |
| Whether lack of probable cause defeats exigent-entry justification | Exigency could overcome lack of probable cause | Probable cause required for exigent entry | Lack of probable cause defeats exigent-entry justification; Fourth Amendment violation |
| Whether the officers' actions were objectively reasonable for qualified immunity | All four violated clearly established rights | Some actions could be reasonable under Brigham City framework | Roberts and Munoz: qualified immunity; Ryburn and Zepeda: not entitled |
Key Cases Cited
- Hopkins v. City of San Jose, 573 F.3d 752 (9th Cir. 2009) (exigent circumstances and lack of probable cause require justification)
- Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency-aid exception requires objectively reasonable basis for emergency)
- LaLonde v. County of Riverside, 204 F.3d 947 (9th Cir. 2000) (probable cause is required for warrantless home entry when relying on exigency)
- Payton v. New York, 445 U.S. 573 (U.S. 1980) (core Fourth Amendment line at the entrance to the home; warrantless entry generally prohibited)
- Michigan v. Fisher, 130 S. Ct. 546 (U.S. 2010) (emergency-aid exception refined; requires objective basis for immediate aid)