City and County of San Francisco v. Sheehan

**Question the Court was asked to decide** 1. Does the Americans with Disabilities Act (ADA) require police officers to provide a “reasonable accommodation” for a person who is both mentally ill and armed when they are trying to make an arrest? 2. Are the two officers protected by **qualified immunity** – a legal shield that keeps government officials from being sued unless they violated a constitutional right that was “clearly established” at the time? **What the Court held** * The first question was **dismissed as “improvidently granted.”** In other words, the Supreme Court decided it should not rule on whether the ADA applies in this exact situation because the lower courts had not addressed the correct legal argument. * On the second question, the Court held that the officers **are entitled to qualified immunity**. The Court said the officers did **not** violate any clearly‑established Fourth Amendment right (the part of the Constitution that protects people from unreasonable searches and seizures) when they re‑entered the room and used force. **Why the Court reached that result** * **ADA issue:** The Court noted that the city had argued a different point than the one the lower courts had decided. Because the parties did not properly frame the ADA question before the Court, the justices chose to drop it rather than decide a point that had not been properly presented. * **Qualified‑immunity issue:** To strip an officer of qualified immunity, a plaintiff must show that the officer violated a constitutional right that was clearly defined at the time of the incident. The Court looked at existing case law and found **no precedent** saying that police must first try to accommodate a suspect’s mental‑illness before using force, even when the suspect is armed and threatening. The officers’ decision to re‑enter the room and later use pepper spray and, when that failed, gunfire was judged **reasonable** under the circumstances (the suspect had a knife, had threatened to kill them, and the officers could not see what she might do next). Because the law was not clear that the officers had to act differently, the Court said they are protected by qualified immunity. **How the justices voted** * **Majority (6 justices):** Justice Alito wrote the opinion, joined by Chief Justice Roberts and Justices Kennedy, Thomas, Ginsburg, and Sotomayor. * **Partial dissent:** Justice Kagan filed an opinion concurring in part and dissenting in part (joined by herself). * **No participation:** Justice Breyer did not take part in the case. In short, the Supreme Court left the ADA question unresolved and protected the officers from liability because the law did not clearly require them to accommodate the woman’s disability before using force.