City and County of San Francisco v. Sheehan

(1) Whether police officers must make "reasonable accommodations" under the American with Disabilities Act when they are making an arrest of violent armed individual; and (2) whether entry into a residence, even though there is a clear exception to the warrant requirement can still be unreasonable under the Fourth Amendment.

Petitioners, police officers, were dispatched to aid in detaining Respondent, a mentally ill individual, who was making violent threats for an involuntary psychiatric evaluation that Respondent’s social worker deemed was necessary. Petitioners attempted to enter Respondent’s room, and Respondent charged Petitioners with a knife. After retreating, Petitioners reentered the room to disarm Respondent and in order to keep from being injured; Petitioners fired four shots into Respondent, who survived.

Respondent filed suit claiming Petitioners violated her Fourth Amendment Rights and violated her right to “reasonable accommodation” under Title II of the Americans With Disabilities Act (“ADA”). The district court granted Petitioners’ motion for summary judgment on the grounds that there was no authority that that mandated Petitioners ascertain whether or not their action in protecting themselves or others comply with the ADA before taking action. The district court also held there was no violation of Respondent Fourth Amendment Rights as the Petitioners entry satisfied the emergency aid exception to the warrant requirement. The Court of Appeals affirmed in part and vacated in part holding that ADA does apply to arrests and there was a triable issue as to whether the Petitioners used unreasonable deadly force and whether Petitioners failed to make reasonable accommodations under the ADA during the arrest. The court remanded for further proceedings after vacating the summary judgment.

The Court granted certiorari to resolve a split among the circuits as to whether or not the “reasonable accommodation” requirement under the ADA applies to arrests.