The Supreme Court has once again overruled the Ninth Circuit Court of Appeals, this time in a warrantless entry case.
The Court issued a per curiam opinion Monday morning in Ryburn v. Huff, finding that officers who entered a suspect's home without a warrant while investigating a threatened school shooting acted reasonably under the rapidly-escalating circumstances, and were protected by qualified immunity.
In 2007, Burbank police went to then-high school student Vincent Huff's home to question him about a rumored letter in which Vincent allegedly threatened to "shoot up" the school. Police knocked and announced themselves several times at the home, but no one answered the door. When one of the officers reached Vincent's mother, Maria Huff, on her cell phone, she informed the officer that both she and Vincent were inside the house.
Maria and Vincent walked out of the house to speak with the officers, and declined the officers' request to talk inside. When asked if there were any guns inside the house, Maria "immediately" turned and ran into the house. Several of the officers followed Maria into the house out of fear for their personal safety. Two additional officers, who were out of earshot for the exchange, also entered the house, assuming that the other officers had permission to enter.
The officers ultimately concluded that the rumor was unsubstantiated, and left. The Huffs responded with a warrantless entry claim.
A district court in California found that the officers' action was a warrantless entry in violation of the Fourth Amendment, but ruled that the officers were protected by qualified immunity. The Ninth Circuit Court of Appeals reversed the district court, reports the Los Angeles Times.
The Supreme Court, however, noted that reasonable officers in the petitioners' position could have come to the conclusion that the Fourth Amendment permitted the warrantless entry because there was an objectively reasonable basis for fearing that violence was imminent. The Court noted that the Ninth Circuit's approach to the case was "entirely unrealistic," and reminded that appellate panel that "reasonableness must be judged from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight."
The Ryburn qualified immunity decision was not the High Court's only Ninth Circuit Court of Appeals reversal of the day. The Nine also reversed the circuit in National Meat Association v. Harris, ruling that the Federal Meat Inspection Act preempts a California statute that prohibits slaughterhouses from buying, selling, or receiving non-ambulatory swine.
- Ryburn v. Huff (Supreme Court)
- Exigent Circumstances? Flushing Justifies Warrantless Entry (FindLaw's Tenth Circuit blog)
- Unanimous: Warrantless GPS Tracking is Unreasonable Search (FindLaw's Supreme Court blog)
- Slaughterhouse Nine: Federal Preemption Bars Cal Meat Law (FindLaw's California Case Law blog)