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SCOTUS: Question of ADA Accommodations for Mentally Ill Suspects Unanswered

By Christopher Coble, Esq. on May 19, 2015 | Last updated on March 21, 2019

Lately, we've heard a lot of discourse and protest about excessive use of police violence against minorities. However, there is an equally vulnerable minority group, the mentally ill and disabled, who are also frequent victims of police force.

In the case of City and County of San Francisco v. Sheehan, the Supreme Court considered whether Title II of the Americans with Disabilities Act requires police to provide accommodations to armed and violent mentally ill suspects. The Court also looked at whether the Fourth Amendment clearly establishes that officers cannot forcibly enter the home of an armed, mentally ill subject when there was no immediate need.

In its ruling, the Court sidestepped both issues.

The Case

In August 2008, Teresa Sheehan, who has schizoaffective disorder, lived in a group home for people with mental illnesses. A social worker, Heath Hodge, concerned about Sheehan's condition because she stopped taking her medication visited her to conduct a welfare check.

When Hodge entered Sheehan's room, she claimed to have a knife and threatened to kill Hodge. He immediately left her room, evacuated the building, and called the police. When officers Reynolds and Holder arrived, they entered Sheehan's room and were similarly threatened. This time Sheehan had a knife.

Reynolds and Holder left the room, and called for backup. But while they waited, the two officers worried that Sheehan was a danger to herself and others, so they entered her room a second time. Sheehan was still aggressive and threatening. The officers tried to pepper spray her, but she did not drop her knife. With Sheehan only a few feet away, Holder shot her twice, and Reynolds fired more shots when Sheehan did not collapse.

After surviving her injuries, Sheehan sued San Francisco, alleging that the city violated the Americans with Disabilities Act by not reasonably accommodating her disability. She also sued officers Reynolds and Holder for violating her Fourth Amendment rights.

Lower Court Rulings

The District Court granted summary judgment to San Francisco, holding that officers are "not required to first determine whether their actions would comply with the ADA before protecting themselves" and did not violate the Fourth Amendment.

The Ninth Circuit Court of Appeals ruled that a jury should decide whether San Francisco should have "accommodated Sheehan by 'respecting her comfort zone, engaging in nonthreatening communications and using time to diffuse the situation.'" The court also found that the Fourth Amendment required officers to accommodate Sheehan's mental illness.

Supreme Court Ruling

In its decision, the Supreme Court did not address whether or not Title II of the ADA or the Fourth Amendment imposed a duty to accommodate a mentally ill person. The court only ruled that since the duty was not clearly established seven years ago when the incident happened, that the officers had a legal immunity because they acted reasonably.

The case will now return to the Ninth Circuit.

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