Decision here.
Regarding qualified immunity, the Court found the following: The police were initially justified in making entry into Sheehan's room because law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury. After they closed the door, they were justified in opening it again for the exact same reason; and also because the two entries were really part of a single, continuous search. Besides, they knew that Sheehan was armed, that she had just threatened to kill three people, and that delay could make the situation more dangerous. Even if some idiot former chief of police testified that the officers should have tried harder to find non-violent solutions, the actions that they took here were reasonable. Subduing Sheehan with pepper spray (or trying to) was reasonable, and when that proved ineffective and she was approaching officers with a knife, shooting her was reasonable. So since all of that was acceptable under Constitutional standards, we're back to the first question of whether the officers violated Sheehan's rights by not accommodating her disability and respecting her comfort zone.
The Ninth Circuit continues its quest to be the most reversed Federal court EVAR.
Sheehan was living in a group home for people with mental illness, and wasn't doing so well. She had stopped taking her meds, stopped communicating with her therapist, and stopped changing her clothes. When a social worker went to check on her, she threatened to kill him with a knife (he didn't actually stop to see whether or not she really had a knife, but she did). He backed out and called the police for help. He also completed the paperwork to have her taken in for a mental evaluation, noting on the form that she was a danger to others and gravely disabled.
After the first two cops showed up, reviewed the paperwork, and had a hospital ready to admit Sheehan, they knocked on her door and told her they were there to help her. When she didn't answer, they opened the door. She sprang at them with a knife, and they closed the door. They called for more help, but decided to take immediate action because they were dealing with an armed, violent, unstable person who they feared might be escaping, gathering more weapons, or harming someone else (they hadn't at this point determined whether there was anyone else in the room, although Sheehan asserts that they somehow would have been able to see that there wasn't).
One officer pushed the door open again, and the other tried to subdue Sheehan with pepper spray. When that didn't work, and when she continued to approach the officers without dropping the knife, both of them shot her multiple times. Another officer arrived and kicked the knife out of Sheehan's hand (now that she was subdued), and she was taken into custody.
Sheehan survived. A jury deadlocked on the charges against her, and the prosecutors didn't bother to retry the case. Then Sheehan sued the city and the officers who shot her, for an alleged violation of the Americans with Disabilities Act. The argument is essentially that the police should have accommodated her disability during the arrest by "respecting her comfort zone" and waiting until she calmed down. I'd say that you can't make this stuff up, but someone obviously did... anyway, the Ninth Circuit denied qualified immunity, holding that a jury could reasonably find that the officers force the confrontation and that it's clearly established that you can't enter the home of an armed, mentally ill person when there's no objective need to do so.
The Supreme Court granted cert on a couple of issues: first, on whether the ADA even applies to making arrests; and second, on whether or not the officers are entitled to qualified immunity. But San Francisco's attorney's botched the argument so badly that the Supreme Court changed it's mind about cert on the first issue, and decided not to decide whether or not the ADA applies to making arrests. So the lower courts can have fun with that.
Regarding qualified immunity, the Court found the following: The police were initially justified in making entry into Sheehan's room because law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury. After they closed the door, they were justified in opening it again for the exact same reason; and also because the two entries were really part of a single, continuous search. Besides, they knew that Sheehan was armed, that she had just threatened to kill three people, and that delay could make the situation more dangerous. Even if some idiot former chief of police testified that the officers should have tried harder to find non-violent solutions, the actions that they took here were reasonable. Subduing Sheehan with pepper spray (or trying to) was reasonable, and when that proved ineffective and she was approaching officers with a knife, shooting her was reasonable. So since all of that was acceptable under Constitutional standards, we're back to the first question of whether the officers violated Sheehan's rights by not accommodating her disability and respecting her comfort zone.
The Supreme Court held that the officers didn't violate any clearly established right and therefore are entitled to qualified immunity.
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