Skip to main content

Police accommodations for mental illness

City and County of San Francisco v. Sheehan

Updated Oct 18, 2026

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.

Illustration for City and County of San Francisco, California v. Teresa Sheehan
Conceptual illustration · AI-generated

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

  • Joined the judgment
  • Dissented
  • Wrote an opinion
Majority · 6joined the Court's opinion
  1. Thomas
  2. Kennedy
  3. Ginsburg
  4. Sotomayor
  5. Roberts
  6. Alitowrote the opinion
Dissenting · 2disagreed with the result
  1. Kagan
  2. Scaliawrote the dissent
6 justices joined the judgment, 2 dissented.

From the opinions

“Petitioners had expressly advocated for the Fifth and Sixth Circuits’ position in the Court of Appeals.”

— Justice Scalia(dissent)

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

1

Docket activity

9
  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Case Briefing

    Oct 18, 2026 · Generated

  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Impact Analysis

    Oct 18, 2026 · Generated

  • AI analysis generated: Opinion Summary

    Oct 18, 2026 · Generated

Show 4 more
  • AI analysis generated: Decision Record

    Oct 18, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Oct 18, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Oct 17, 2026 · Court records

  • Opinion added: Sheehan

    May 18, 2015 · Court records

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.

Checked Oct 18, 2026Methodology

Court records and filings

Reporting and analysis