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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.


1. Whether Title II of the Americans with Disabilities Act (ADA) requires law enforcement officers to provide accommodations to an armed, violent, and mentally ill suspect in the course of bringing the suspect into custody.

2. Whether it was clearly established that even where an exception to the warrant requirement applied, an entry into a residence could be unreasonable under the Fourth Amendment by reason of the anticipated resistance of an armed and violent suspect within.


1. The Supreme Court dismissed the first question presented because at oral argument the city did not argue the issue presented in the question. Instead of arguing that the ADA did not apply to enforcement actions by law enforcement officers, the city conceded that the ADA might apply to arrests. The city then argued that in this case, the officers were not required to provide Sheehan an accommodation under the ADA because of the threat she posed to the officers. Because the Supreme Court does not usually decide questions of law that were not presented to, and ruled upon by a lower court, it decided to dismiss the first question presented by the city.

2. No, it was not clearly established; therefore, the officers were entitled to qualified immunity.


The court held the case law relied upon by the Ninth Circuit in denying the officers qualified immunity did not clearly establish that it was unreasonable for the officers to forcibly enter the home of an armed, mentally ill suspect who had been acting irrationally and threatening others when there was no objective need for immediate entry. In addition, even if the officers acted contrary to the training they received on how to deal with mentally ill subjects, the court held at the time of the incident is was not clearly established that the Fourth Amendment required the officers to accommodate Sheehan’s mental illness before attempting to arrest her.


575 U.S. ___, 135 S. Ct. 1765 2015)

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