Ryburn v. Huff
132 S. Ct. 987
| SCOTUS | 2012Background
- Police responded to a school threat rumor at Bellarmine-Jefferson High School; school officials requested investigation.
- Interviews revealed Vincent Huff had been absent and bullied; others believed he could be capable of violence.
- Officers learned of potential weapons and safety risks; they proceeded to interview Vincent at his home.
- Mrs. Huff did not permit interviewing inside; she refused to discuss guns and then hung up when contacted by the officers.
- Huff and Vincent walked outside; officers entered the home without a warrant, citing safety concerns and potential weapons.
- After a brief stay, officers concluded the rumor was false and reported their findings; district court granted qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the warrantless entry justified by probable imminent danger? | Ryburn | Huff | Yes; reasonable belief of imminent danger supported entry |
| Did the Ninth Circuit err in denying qualified immunity to petitioners? | Ryburn | Huff | No; officers could reasonably believe entry was necessary |
| Should the court reassess the District Court's factual findings for reasonableness? | Ryburn | Huff | Yes; court must view facts as seen by a reasonable officer |
| Do on-scene safety concerns allow sweeping, non-consensual home entry even without objective evidence of weapons? | Ryburn | Huff | Yes; rapidly evolving situations permit warrantless entry |
Key Cases Cited
- Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (imminent threat justifies warrantless entry)
- Georgia v. Randolph, 547 U.S. 103 (U.S. 2006) (respecting residence entry for safety considerations)
- Graham v. Connor, 490 U.S. 386 (U.S. 1989) (reasonableness judged from perspective of officer on scene)
- Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (emergency or exigency justifies otherwise illegal acts)
