City & Cnty. of San Francisco v. Sheehan

Sheehan, a woman who suffered from mental illness, lived in a group home that accommodated such persons. Sheehan’s social worker became concerned about her deteriorating condition because Sheehan was not taking her medications. When the social worker entered Sheehan’s room, Sheehan told the social worker to get out. In addition, Sheehan told the social worker she had a knife and threatened to kill him. The social worker left Sheehan’s room, cleared the building of other residents and called the police to help him transport Sheehan to a mental health facility for an involuntary commitment for evaluation and treatment. When Officers Reynolds and Holder arrived, the social worker told them he had cleared the building of other residents. The social worker also told the officers the only way for Sheehan to leave her room was by using the main door, as the window in Sheehan’s room could not be used as a means of escape without a ladder. The officers then entered Sheehan’s room without a warrant to confirm the social worker’s assessment, and to take Sheehan into custody. When Sheehan saw the officers, she grabbed a knife and threatened to kill them, stating she did not wish to be taken to a mental health facility. The officers went back into the hallway and closed the door to Sheehan’s room. The officers called for back-up, but before other officers arrived, Reynolds and Holder drew their firearms and forced their way back into Sheehan’s room. After Sheehan threatened the officers with a knife, the officers shot Sheehan five or six times. Sheehan survived and sued the city and the officers, claiming the officers violated her Fourth Amendment rights by entering her room without a warrant and using excessive force. Sheehan also claimed the officers did not follow department training on how to deal with mentally ill subjects.