Police accommodations for mental illness
City and County of San Francisco v. Sheehan
In brief
The Court protected Officers Reynolds and Holder from liability under qualified immunity but did not decide whether the Americans with Disabilities Act required accommodations.
- Where it stands
- Decided
Decided 6-2 · May 18, 2015 · Opinion by Justice Alito
- What it’s about
- Sheehan challenged San Francisco officers’ second forced entry into her room.
- Who it affects
- The ruling protects Officers Reynolds and Holder from liability to Sheehan for her injuries.
Summary: written with AI from the case record.

What it's about
The Court ruled Officers Reynolds and Holder could not be held liable under a rule protecting officials unless they violate a clearly established right (qualified immunity), but declined to decide whether the Americans with Disabilities Act required accommodations (dismissed that question as improvidently granted).
The case combined a challenge to the officers’ second entry with a question about accommodations under the Americans with Disabilities Act during an arrest.
Question presented
1. Did the officers violate a clearly established right under the Fourth Amendment when they forced entry into Sheehan’s room the second time? 2. Does the Americans with Disabilities Act require law enforcement officers to provide accommodations to an armed, violent and mentally ill suspect when attempting to take that suspect into custody?
What the Court decided
Holding
The question whether §12132 “requires law enforcement officers to provide accommodations to an armed, violent, and mentally ill suspect in the course of bringing the suspect into custody,” Pet. for Cert. i, is dismissed as improvidently granted. Certiorari was granted on the understanding that San Francisco would argue that Title II of the ADA does not apply when an officer faces an armed and dangerous individual. Reynolds and Holder are entitled to qualified immunity from liability for the injuries suffered by Sheehan. Public officials are immune from suit under 42 U. S. C. §1983 unless they have “violated a statutory or constitutional right that was ‘ “ ‘clearly established’ ” ’ at the time of the challenged conduct,” Plumhoff v. Rickard, 572 U. S. ___, ___, an exacting standard that “gives government officials breathing room to make reasonable but mistaken judgments,” Ashcroft v. al-Kidd, 563 U. S. ___, ___. 10–
- Result
- Dismissed
The Court's reasoning
The Court said officials can be held liable only if they violate a right that was clearly established at the time. It described this demanding rule as giving officials room to make reasonable mistakes.
The vote
From the opinions
“Petitioners had expressly advocated for the Fifth and Sixth Circuits’ position in the Court of Appeals.”
What's next
The ruling protects the two officers from liability for Sheehan’s injuries. The Court did not decide the ADA question in this case.
Documents
Opinions
Docket activity
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AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
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Opinion added: Sheehan
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.