San Francisco v. Sheehan
Issues
What is the scope of reasonable police officer action under Title II of the ADA and the Fourth Amendment when dealing with armed and violent, mentally ill individuals?
The Supreme Court will determine whether the ADA requires police officers, when attempting an arrest, to reasonably accommodate a violent and armed, mentally ill suspect. San Francisco argues that Sheehan, the suspect in this case, posed a direct threat to others and, accordingly, the ADA did not apply. Moreover, San Francisco contends that, at the least, the officers did not violate a clearly established right and, thus, are protected from liability by qualified immunity. Sheehan counters that she posed a threat only to people that entered her room and that the officers’ action violated her clearly established right to be free from unreasonable seizures. The Court’s ruling will have an effect on the safety of the public, the mentally ill, and law enforcement officers.
Questions as Framed for the Court by the Parties
- Whether Title II of the Americans with Disabilities Act requires law enforcement officers to provide accommodations to an armed, violent, and mentally ill suspect in the course of bringing the suspect into custody.
- Whether it 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.
In 2008, Respondent Teresa Sheehan, who has a mental illness, was a resident at the Conrad House, a group home in San Francisco for the mentally ill. See Sheehan v. San Francisco, 743 F.3d 1211, 1217 (9th Cir. 2014). After a social worker, Heath Hodge, entered Sheehan’s room without her permission to check on her, Sheehan told Hodge to leave and threatened him after stating that she had a knife.
Edited by
Additional Resources
- Lyle Denniston: Court to rule on disability rights, mercury pollution, SCOTUSblog (Nov. 25, 2014).
- Jessie Lorenz: SF appeal threatens protections for the disabled, The San Francisco Examiner (Jan. 20, 2015).
- Richard Wolf: Justices to decide rights of disabled during arrests, USA Today (Nov. 25, 2014).