Ryburn v. Huff, 565 U.S. 469 (Jan. 23, 2012)

The Court reversed a Ninth Circuit ruling that officers were not entitled to qualified immunity in a § 1983 action that arose after the officers entered a home without a warrant. When officers responded to a call from a high school, the principal informed them that a student, Vincent Huff, was rumored to have written a letter threatening to “shoot up” the school. The officers learned that Vincent had been absent two days, that he was a victim of bullying, and that a classmate believed him to be capable of carrying out the alleged threat. Officers found these facts concerning in light of training suggesting to them that these characteristics are common among perpetrators of school shootings. When the officers went to Vincent’s home and knocked at the door, no one answered. They then called the home phone and no one answered. When they called Vincent’s mother’s cell phone, she reported that she and Vincent were inside. Vincent and Mrs. Huff then came outside to talk with the officers. Mrs. Huff declined an officer’s request to continue the discussion inside. When an officer asked Mrs. Huff if there were any guns in the house, she immediately turned around and ran inside. The officers followed and eventually determined the threat to be unfounded. The Huffs filed a § 1983 action. The District Court found for the officers, concluding that they were entitled to qualified immunity because Mrs. Huff’s odd behavior, combined with the information the officers gathered at the school, could have led reasonable officers to believe that there could be weapons inside the house, and that family members or the officers themselves were in danger. A divided panel of the Ninth Circuit disagreed with the conclusion that the officers were entitled to qualified immunity. The U.S. Supreme Court reversed, determining that reasonable officers could have come to the conclusion that the Fourth Amendment permitted them to enter the residence if there was an objectively reasonable basis for fearing that violence was imminent. It further determined that a reasonable officer could have come to such a conclusion based on the facts as found by the trial court.