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Ryburn v. Huff
132 S. Ct. 987
| SCOTUS | 2012
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Background

  • 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)
Read the full case

Case Details

Case Name: Ryburn v. Huff
Court Name: Supreme Court of the United States
Date Published: Jan 23, 2012
Citation: 132 S. Ct. 987
Docket Number: 11-208
Court Abbreviation: SCOTUS