In a per curiam opinion, the Court found that officers were entitled to qualified immunity for the violation of the Fourth Amendment based on a fear for officer safety. Prior to this case, officers were entitled to immunity in cases where they entered a home without a warrant with the objectively reasonable belief that a person inside was in imminent danger of serious harm. Now, officers are immune from suit if they fear imminent danger to themselves.
The suit was originally filed under 42 U.S.C. §1983, which allows lawsuits by individuals for violations of constitutional or legal rights by the government. The plaintiffs, the Huffs, claimed that police violated the Fourth Amendment by entering their home without a warrant, and the police officers argued that they were entitled to qualified immunity from the suit. Generally, an officer performing a discretionary function enjoys qualified immunity in a civil action for damages, as long as he does not violate established constitutional or legal protections.
Police had been investigating a rumor that Vincent Huff had threatened in a letter to “shoot up the school.” After a request by the principal, and finding that Vincent fit the profile of a school shooter—he had been bullied; another student thought he was “capable” of violence—the police went to Huff’s home. Four officers arrived at the house, knocked repeatedly and received no answer. They then called the house phone repeatedly and received no answer. They then called Vincent’s mother’s cell phone. Mrs. Huff answered and told police she was in the house, but ended the call abruptly. She emerged from the house a few minutes later with Vincent, declining the police’s suggestion that they protect Vincent by talking inside, which police found “extremely unusual.” Police also were surprised that Mrs. Huff never asked about the reason for the visit.
The police then asked if there were any guns in the house. In response, Mrs. Huff immediately turned and ran into the house. Afraid for their safety, the two officers closest to the house entered after her. Having been out of earshot of the conversation, the other two officers followed on the assumption that consent had been given to enter the house. The officers were in the house for 5-10 minutes before they were challenged by Mr. Huff and told to leave. The rumor of Vincent’s threats against the school was ultimately found to be false.
As noted above, the Court’s interpretation of the Fourth Amendment allows police officers to enter a house without a warrant when they have an objectively reasonable basis for believing that an occupant is imminently threatened with serious injury. If a court finds that these exigencies exist, qualified immunity protects the officers from suit.
In this case, the Court found that given the Huff’s odd behavior described above, the specific threats under investigation and Mrs. Huff’s decision to run into the house when police asked about guns, there was an objectively reasonable basis for the police to fear an imminent threat to officer safety and to enter. Specifically, the Court found that the Ninth Circuit improperly reviewed the District Court’s findings of fact, improperly characterized Mrs. Huff’s flight into the house as an innocent termination of the encounter, improperly evaluated the objective reasonableness based on each element of the situation (not answering phones, not answering knocking, etc.) instead of on the combined circumstances; and improperly looked at the encounter with “20/20 hindsight” instead of through the eyes of the police at the time.
The Court has opened a door wide for qualified immunity for violations of Constitutional rights based on fear for “officer safety.” The Court has specifically admonished that lower courts should evaluate these situations through the eyes of officers at the scene by looking at all of the circumstances, which will make it much harder for litigants to bring successful claims.