January 23, 2012

Supreme Court Decides Ryburn v. Huff

On January 23, 2012, the Supreme Court decided Ryburn v. Huff, No. 11-208, holding that police officers who entered the private residence of a California family without a warrant, believing that the family or the officers were in danger, were entitled to qualified immunity in a lawsuit brought under 42 U.S.C. § 1983. 

Burbank Police Department Officers Darin Ryburn and Edmundo Zepeda learned of school officials' concerns that a student, Vincent Huff, had written a letter threatening to "shoot up" the school.  Officers Ryburn and Zepeda investigated and discovered that Huff had been bullied at school, had been absent for two days, and that one classmate believed Huff capable of carrying out the threat.  Ryburn and Zepeda proceeded to Huff's home.  No one answered the door or the telephone after the officers knocked and announced their presence and tried to call the Huffs.  When Ryburn called Mrs. Huff's cell phone, she nevertheless indicated that she was inside the home with her son.  The two proceeded outside to be interviewed.  When the officers asked whether there were any guns in the house, Mrs. Huff immediately turned around and ran into the house, followed by her son.  Without a warrant, the officers proceeded inside and continued the interview there.  Eventually the officers concluded that the rumor about the school shooting was false, and they reported their conclusion to the school. 

The Huffs brought a civil rights suit under 42 U.S.C. § 1983, alleging that the officers violated the Huffs' Fourth Amendment rights by entering their home without a warrant.  The District Court entered judgment in the officers' favor, finding that they were entitled to qualified immunity.  A divided panel of the United States Court of Appeals for the Ninth Circuit reversed, holding that the officers acted in an objectively unreasonable manner in entering the home without a warrant.

The Supreme Court granted review and summarily reversed the Ninth Circuit in a unanimous opinion, holding that the officers were entitled to qualified immunity because there was "an objectively reasonable basis for fearing that violence was imminent."  The Court noted that the need to protect and preserve life and to avoid serious injury "is justification for what would be otherwise illegal absent an exigency or emergency."  A number of factors in Huff's case supported the Court's decision, including the unusual behavior of the parents in not answering the door or the telephone, Mrs. Huff's act of running back into the house after the officers asked about the presence of guns, Vincent's absence from school, and his status as a victim of bullying.

The Court issued its decision in a unanimous per curiam opinion.

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