In Ryburn v. Huff, published January 23, 2012, the U.S. Supreme Court reversed a divided Ninth Circuit decision that the defendant police officers were not entitled to qualified immunity for entering the plaintiffs' home without a warrant. The defendant officers visited the home of a high school student, investigating rumors that the student had written a letter threatening to shoot up the school. The student had been absent from school for two days, and was frequently bullied. When the officers visited, they received no response to their knocks on the door or their calls to the home telephone. The officers called the student's mother's cell phone and talked to the mother. She stated she was inside the house with the student. When the officers stated they were at the house, she hung up on them. The mother and student went outside and spoke with the officers. The mother declined the officers' request to enter the home to discuss the matter. When the officers asked if there were guns in the house, the mother turned and ran inside the house. The officers followed her. They eventually determined the rumors were false. The family sued the officers under 42 USC section 1983 for violating their Fourth Amendment rights. The district court entered judgment in favor of the officers, finding that they were entitled to qualified immunity because the officers could reasonably believe they were in danger.
The Supreme Court, per curiam, upheld the district court's decision. The Ninth Circuit majority, in reversing the district court, erred in viewing each of the plaintiffs' acts in isolation; and by concluding that because each was lawful, none supported a reasonable conclusion that the officers were in danger. Viewed together, the information from the school and the mother's evasive behavior supported a reasonable fear of danger. The entry into the house did not violate the Fourth Amendment.
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