Supreme Court of the United States
County of Los Angeles, California, Petitioners v. Angel Mendez
May 30, 2017581 U.S. 420
Summary
The Supreme Court rejected the Ninth Circuit's 'provocation rule,' under which officers whose defensive use of force is objectively reasonable under Graham v. Connor may nonetheless be held liable for excessive force when a separate Fourth Amendment violation intentionally or recklessly provoked the violent confrontation. The Court held that a distinct Fourth Amendment violation cannot transform a later, reasonable use of force into an unreasonable seizure, and that excessive force claims must be analyzed exclusively under Graham's objective reasonableness framework, separately from other Fourth Amendment claims. Finding that the Ninth Circuit's alternative proximate-cause rationale conflated distinct claims and focused on the wrong predicate violation, the Court vacated the judgment and remanded for reconsideration of whether the warrantless entry proximately caused the shooting injuries. No separate writings were filed.
Holding
- Whether the Fourth Amendment provides a basis for the Ninth Circuit's provocation rule imposing excessive force liability when a separate Fourth Amendment violation provoked a violent response to an otherwise reasonable use of force.. No. The Fourth Amendment provides no basis for such a rule; a different Fourth Amendment violation cannot transform a later, reasonable use of force into an unreasonable seizure. Once a use of force is deemed reasonable under Graham, it may not be found unreasonable by reference to some separate constitutional violation.
- Whether the Court of Appeals' alternative proximate-cause rationale supported holding the deputies liable for the shooting based on the warrantless entry.. No. The Court of Appeals' proximate cause analysis was tainted by the same errors underlying the provocation rule: it focused solely on risks foreseeably associated with a startling unannounced entry—a knock-and-announce violation for which the officers had qualified immunity—rather than identifying the foreseeable risks associated with the relevant constitutional violation (the warrantless entry), and it did not explain how respondents' injuries were proximately caused by that entry. The proximate cause question must be revisited on remand.
Docket 16–369.