Teresa Sheehan v. City and County of San Francis, 2014 U.S. App. LEXIS 3321

Background

Teresa Sheehan, a mentally ill woman in a San Francisco group home, faced a 72-hour involuntary detention under Cal. Welfare & Inst. Code § 5150.
Hodge, a social worker, sought police assistance to transport Sheehan to a mental health facility after deeming her gravely disabled and dangerous.
Officers Reynolds and Holder entered Sheehan’s room without a warrant to assess her condition and take her into custody; Sheehan threatened them with a knife.
After retreating, officers forcibly reentered with backup, resulting in Sheehan being shot five to six times during a confrontation in a confined space.
Sheehan filed a 42 U.S.C. § 1983 action alleging Fourth Amendment violations, ADA discrimination, and state-law claims; the district court granted summary judgment to defendants.
Key issues include whether the initial entry, second entry, and deadly force were reasonable under the Fourth Amendment, and whether Monell, ADA, and state-law claims survive.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the initial entry was lawful under the emergency aid exception	Sheehan contends the entry violated the Fourth Amendment.	Defendants argue emergency aid justified initial entry and conduct was reasonable.	Initial entry lawful under emergency aid; triable issues remain for second entry.
Whether the second entry violated the Fourth Amendment	Second entry was unreasonable and escalated danger.	Second entry could be justified by emergency aid or exigent circumstances.	Triable issues exist; not entitled to judgment as a matter of law on reasonableness and force used.
Whether the shooting violated the Fourth Amendment or was provoked by officers	Officers provoked a deadly confrontation by forced entry without adequate accommodation for mental illness.	Deadly force reasonable given immediate threat from a knife.	Triable issues on provocation; partial qualified immunity on final shot; deadly force reasonable at moment of shooting but potential provocation questions remain.
Whether ADA Title II applies to arrests and reasonable accommodation claim	Failure to reasonably accommodate Sheehan’s disability during the incident violated Title II.	ADA applies; exigent circumstances inform reasonableness of accommodations.	ADA Title II applies to arrests; triable issue on failure to reasonably accommodate.
Whether Monell claims survive and immunities apply to state-law claims under § 5278	City’s failures or ratification exposed Monell liability.	Training was adequate and there was no ratification; § 5278 immunizes detention-related claims.	Monell claims properly granted summary judgment; § 5278 immunity does not bar all state-law claims; remand on immunity issues.

Key Cases Cited

Graham v. Connor, 490 U.S. 386 (U.S. 1989) (balance of intrusion and governmental interests in reasonableness of force)
Alexander v. City & County of San Francisco, 29 F.3d 1355 (9th Cir.1994) (storming mentally ill recluse case; noncompliant entry and provocation doctrine)
Fisher v. City of San Jose, 558 F.3d 1069 (9th Cir.2009) (continuous search doctrine; emergency aid/exigent circumstances interplay)
Deorle v. Rutherford, 272 F.3d 1272 (9th Cir.2001) (distinct treatment of emotionally disturbed individuals; force considerations)
Billington v. Smith, 292 F.3d 1177 (9th Cir.2002) (provocation theory for the use of deadly force in Fourth Amendment)
Reynolds v. County of San Diego, 84 F.3d 1162 (9th Cir.1996) (use of force and reasonable accommodation considerations; expert evidence admissibility)
Trevino v. Gates, 9th Cir. 1996 (9th Cir.1996) (monell-like considerations for municipal liability)
Waller ex rel. Estate of Hunt v. City of Danville, 556 F.3d 171 (4th Cir.2009) (ADA Title II reasonable accommodation; exigency informs reasonableness)
Gohier v. Enright, 186 F.3d 1216 (10th Cir.1999) (ADA applicability to arrests; title II scope)
Michigan v. Fisher, 558 U.S. 45 (U.S. 2009) (emergency aid exception requires only potential serious injury; not ironclad proof)