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The Honorable Court at Officer Resource

US Supreme Court Ryburn v. Huff 11-208

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by , 05-20-12 at 08:29 PM (591 Views)
Decision here.
Discussion here.

Officers received a call that Vincent Huff had threatened to shoot up his school. They interviewed school staff and other students, and learned that Huff had been bullied and was frequently absent (and therefore, based on their training, he met the profile of a school shooter). Huff was not at school, so they went to his house to meet with him.

There was no answer when they knocked on the door, so they tried to call into the house by phone. They eventually got ahold of Huff's mother by cell phone. She told them that she was inside the house with her son, and they told her they wanted to speak with him. She hung up. Eventually, she met with officers in front of the house and brought her son with her. She never asked why the officers were there, and refused to allow the officers into the house, which the officers noted as strange. One of the police asked if there were weapons in the house.

Testimony conficts as to what happened next. Mrs. Huff claims that she said she was going inside to get her husband, the officers claim that she suddenly turned and ran into the house. Four officers followed her into the house (including two who had been standing outside of earshot for this exchange and believed that she had given consent for entry). They all remained in the front room with Vincent and Mrs. Huff, until Vincent's father entered and "challenged the officers' authority to be there." The officers remained in the house for five or ten minutes to conduct their investigation, then concluded that the rumors regarding Vincent's threats were unfounded, and left.

The Huffs sued, and the district court ruled in favor of the officers, saying that they were entitled to qualified immunity. The Huffs appealed, and the Ninth Circuit held that the last two officers to enter the house (who entered on the erroneous belief that consent had been given) were entitled to qualified immunity, but the first two to enter (for officer safety reasons) were not. The Ninth "acknowledged that police officers are allowed to enter a home without a warrant if they reasonably believe that immediate entry is necessary to protect themselves or others from serious harm, even if the officers lack probable cause to believe that a crime has been or is about to be committed," but held that in this case Mrs. Huff was simply asserting her right to end her conversation with the officers and return to her home.

The officers who had now been denied qualified immunity appealed, and the Supreme Court reversed. The Supreme Court held that:
1- Based on current case law, a reasonable officer could have believed that he was justified in making warrantless entry under the circumstances of this case.
2- Although none of Mrs. Huff's actions were illegal, there are many circumstances in which lawful conduct may portend imminent violence.
3- Even when each of the events of a case are mundane when viewed in isolation, they may paint an alarming picture when viewed together.
4- The lower court's second guessing of the officers in this case doesn't jibe with Graham v. Conner. Judged from the perspective of a reasonable officer on the scene, the officers' actions were a reasonable response to Mrs. Huff's behavior.

And so the officers were granted qualified immunity.

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