Stanton v. Sims, 134 S. Ct. 3

Late-night police responded to a disturbance report involving a person with a baseball bat in a high-gang-activity neighborhood.
Officer Stanton spotted three men; one (Patrick) ran about 25 yards ahead and entered a fenced yard belonging to Sims.
Stanton ordered Patrick to stop; Patrick ignored the order and went through a locked gate into Sims’ front yard.
Stanton, fearing for safety and believing Patrick had committed a jailable misdemeanor (Cal. Penal Code §148), kicked open the >6-foot gate in hot pursuit; the swinging gate struck and injured Sims.
Sims sued under 42 U.S.C. §1983 for an unreasonable, warrantless entry into the curtilage of her home (Fourth Amendment).
District Court granted Stanton summary judgment (including qualified immunity); Ninth Circuit reversed, holding entry unconstitutional and qualified immunity unavailable; Supreme Court granted certiorari and reversed the Ninth Circuit on qualified immunity grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether warrantless entry into curtilage in hot pursuit of a fleeing suspect who allegedly committed a misdemeanor violated the Fourth Amendment	Sims: Home/curtilage warrantless entry was unlawful; Welsh supports that warrantless home entries for minor offenses should rarely be allowed	Stanton: Hot pursuit justified immediate entry; officers may enter in hot pursuit regardless of misdemeanor/felony status	Court: Did not decide constitutionality; noted circuit/state courts were divided and precedent was not “beyond debate”
Whether precedent (Welsh, Johnson) clearly established that such an entry was unconstitutional	Sims: Welsh and Ninth Circuit precedent clearly prohibit warrantless home entries for misdemeanors even in pursuit	Stanton: Welsh and Johnson are distinguishable; Santana and other authorities permit hot pursuit entries; law was unsettled	Held: Law was not clearly established; Welsh/Johnson did not make the rule beyond debate
Whether Officer Stanton is entitled to qualified immunity for damages under §1983	Sims: Stanton should not get immunity because the law clearly forbade his conduct	Stanton: Reasonable officer could have believed entry lawful given precedent and exigent circumstances; not "plainly incompetent"	Held: Stanton is entitled to qualified immunity; reversed Ninth Circuit and remanded

Terry v. Ohio, 392 U.S. 1 (1968) (authorizes investigative stops where officer has reasonable suspicion)
United States v. Santana, 427 U.S. 38 (1976) (hot-pursuit entry into dwelling can justify warrantless arrest)
Welsh v. Wisconsin, 466 U.S. 740 (1984) (home entry to arrest for minor/nonjailable offenses generally disfavored)
United States v. Johnson, 256 F.3d 895 (9th Cir. 2001) (warrant required where officers not in continuous/hot pursuit; footnote suggested misdemeanor entries are rarely justified)
Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework permitting courts to decide the constitutional question or the clearly-established-law question first)
Harlow v. Fitzgerald, 457 U.S. 800 (1982) (objective standard for qualified immunity)
Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (existing precedent must place constitutional question beyond debate to deny qualified immunity)
Malley v. Briggs, 475 U.S. 335 (1986) (qualified immunity protects all but the plainly incompetent or those who knowingly violate the law)