City and County of San Francisco, California, Petitioners v. Teresa Sheehan.

Summary

The Supreme Court dismissed as improvidently granted its first question--whether Title II of the ADA requires law enforcement officers to provide accommodations to an armed, violent, and mentally ill suspect in the course of bringing the suspect into custody--because San Francisco abandoned the argument it had pressed in the Ninth Circuit and instead advanced a new 'qualified individual'/direct-threat argument never raised below, leaving the relevant questions without adversarial briefing. On the second question, the Court held that Officers Reynolds and Holder are entitled to qualified immunity because no precedent clearly established that their warrantless reentry of Sheehan's room, without accommodating her mental illness, violated the Fourth Amendment; the Court declined to decide whether a constitutional violation occurred at all, citing inadequate briefing. The Court reversed the Ninth Circuit's judgment and remanded for further proceedings consistent with its opinion.