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County of Los Angeles v. Mendez

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Supreme Court of the United States
County of Los Angeles v. Mendez
Reference: 16-369
Issue: Fourth Amendment
Term: 2016
Important Dates
Argued: March 22, 2017
Decided: May 30, 2017
Outcome
United States Court of Appeals for the 9th Circuit vacated and remanded
Vote
8-0 to vacate and remand
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan


County of Los Angeles, California, v. Mendez is a case argued during the October 2016 term of the U.S. Supreme Court. Argument in the case was held on March 22, 2017. The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit. On May 30, 2017, in a unanimous opinion by Justice Samuel Alito, the court vacated and remanded the judgment of the Ninth Circuit.

In this case, the court struck down a Ninth Circuit rule, known as the provocation rule, because the rule contravened the requirements of the Fourth Amendment. The provocation rule stated that a police officer's otherwise reasonable, lawful defensive use of force was unreasonable as a matter of law if "(1) the officer intentionally or recklessly provoked a violent response and (2) that provocation is an independent constitutional violation." The Supreme Court held that because the rule conflated excessive force claims with other Fourth Amendment claims, the provocation rule permitted excessive force claims that could not succeed as standalone claims under the Fourth Amendment; therefore, the court struck down the rule.[1]

HIGHLIGHTS
  • The case: In the course and scope of their duties in search of a wanted parolee, two L.A. County sheriff's deputies executed a warrantless search of a shack in which two individuals were living. The shack was occupied with the property owner's permission. During the search, which was unannounced, the deputies fired fifteen rounds upon notice that one of the individuals was holding a weapon. The two individuals sustained injuries and were awarded damages for various Fourth Amendment violations. The deputies asserted a claim of qualified immunity, but a trial court and an appellate panel rejected that argument and held the deputies' actions, in part, provoked the events that resulted in the liability judgment.
  • The issue: Were the officers entitled to qualified immunity, and is the theory under which the deputies were held liable for provoking the shooting consistent with the Fourth Amendment?
  • The outcome: On May 30, 2017, the court unanimously vacated and remanded the judgment of the Ninth Circuit.


    • In brief: While executing a warrantless search for a wanted parolee, two L.A. County sheriff's deputies, without notice, searched a shack where they happened upon two occupants who were living in the shack with the homeowner's permission. Upon notice of a weapon held by one of the occupants, the deputies fired fifteen rounds from their service weapons, injuring both occupants. At trial, the deputies asserted qualified immunity for the warrantless search and the resulting injuries sustained by the occupants of the shack, but a trial court and an appellate panel rejected that argument, holding that the deputies' actions were not consistent with the Fourth Amendment and that the deputies were subject to civil liability because the deputies' actions provoked the shooting, which was the proximate cause of the occupants' injuries. Argument in the case was held on March 22, 2017.

    You can review the Ninth Circuit's opinion here.[2]

    Click on the tabs below to learn more about this Supreme Court case.

    Case

    Background

    This is a case about whether two Los Angeles County sheriff's deputies were entitled to qualified immunity pursuant to a search conducted without a warrant and without knocking or announcing their entry. On appeal before the U.S. Supreme Court, this case also reviewed the Ninth Circuit's provocation theory of liability under the Fourth Amendment.

    In October 2010, twelve deputies responded to a call from another officer that Ronnie O'Dell, a wanted parolee, had been spotted entering a local grocery store. O'Dell had been classified as armed and dangerous, which was a standard designation for at-large parolees. The officers searched the store but did not find O'Dell. Afterwards, the officers met to debrief. During the debriefing, another deputy announced that she had received an informant's tip that a man fitting O'Dell's description was in the proximity of a known acquaintance's home, Paula Hughes. In assigning responsibilities, Deputies Christopher Conley and Jennifer Pederson "'were assigned to clear the rear of Hughes property for the officers' safety ... and cover the back door of the Hughes residence for containment.' The officers were told that 'a male named Angel (Mendez) lived in the backyard of the Hughes residence with a pregnant lady (Mrs. Mendez).'" Five deputies, including Conley and Pederson, arrived at the Hughes residence without a search warrant. Conley and Pederson entered the backyard and proceeded to clear the backyard as assigned. According to the circuit panel's opinion,[2]

    “

    Conley and Pederson then proceeded through the backyard toward a 7' x 7' x 7' shack made of wood and plywood. The shack was surrounded by an air conditioning unit, electric cord, water hose, clothes locker (which may have been open), clothes, and other belongings. The deputies did not knock and announce their presence at the shack, and Conley 'did not feel threatened.' Approaching the shack from the side, Conley opened the wooden door and pulled back a blue blanket used as a curtain to insulate the shack. The deputies then saw the silhouette of an adult male holding what appeared to be a rifle pointed at them. Conley yelled 'Gun!' and both deputies fired fifteen shots in total. [3]

    		”

    The weapon turned out to be a BB gun used by Mendez to shoot rats that entered the shack. Mendez testified he was moving it in order to help him sit up. As a result of the deputies' actions, Angel Mendez required amputation of his leg below his right knee and his wife was shot in the back. The Mendezes sued in federal court alleging various Fourth Amendment violations. The court held that the deputies did not meet any exception for a warrantless search and that they violated the Fourth Amendment's knock and announce rule. The court further concluded that the deputies were not subject to qualified immunity. The court awarded the Mendezes approximately four million dollars in damages for the shooting, attorneys' fees, and a $1 penalty for both the unreasonable search and the deputies' failure to knock and announce. The deputies filed notice of appeal as well as a motion to amend the judgment arguing the court committed legal error in denying qualified immunity. The district court denied that motion. The deputies filed a notice of appeal from that decision as well.

    On appeal to the United States Court of Appeals for the 9th Circuit, a three-judge panel concluded thusly:

    • 1. That the shack in question was part of the curtilage of the Hughes residence and, as such, the conduct of the deputies constituted a search under the Fourth Amendment.
    • 2. That the deputies' conduct was not subject to any exception under the Fourth Amendment for a warrantless search, including either a search conducted under exigent circumstances or in hot pursuit of a criminal suspect.
    • 3. That the deputies' argument that Hughes consented to the search was without merit.
    • 4. That the deputies' search failed to constitute a protective sweep because the authority to sweep the Hughes residence in search of O'Dell did not extend to the shack where the Mendezes were living.
    • 5. That the district court's finding that the deputies failed to knock and announce their intention to search was in error because the law at the time of the search was not clearly established.[2]

    The district court awarded damages for the shooting on the basis that the deputies violated the Ninth Circuit's provocation doctrine. The doctrine holds that where "an officer intentionally or recklessly provokes a violent confrontation, if the provocation is an independent Fourth Amendment violation, he may be held liable for his otherwise defensive use of deadly force." The circuit panel agreed with the district court that, because of the illegal warrantless search which was the proximate cause of the Mendezes' injuries, liability was justified. The panel held the deputies were liable as "the shooting was a foreseeable consequence of their unconstitutional entry even though the shooting itself was not unconstitutionally excessive force under the Fourth Amendment."[2]

    The circuit panel affirmed the district court's judgment on the damages for the shooting and the one-dollar award for the warrantless search, reversed the district court's award of one dollar for the knock and announce violation, and remanded the case to the district court with instructions to vacate the knock and announce award.[2]

    Petitioner's challenge

    Los Angeles County, the petitioner, challenged the holding of the United States Court of Appeals for the 9th Circuit that the deputies' actions were in violation of the Fourth Amendment.

    Certiorari granted

    On September 16, 2016, Los Angeles County, the petitioner, initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the United States Court of Appeals for the 9th Circuit. The U.S. Supreme Court granted the county's certiorari request on December 2, 2016, limiting argument to questions 1 and 3 of the petition. Argument in the case was held on March 22, 2017.

    Arguments


    Questions presented

    Questions presented:

    "1. Whether the Ninth Circuit's 'provocation' rule should be barred as it conflicts with Graham v. Connor regarding the manner in which a claim of excessive force against a police officer should be determined in an action brought under 42 U.S.C.§ 1983 for a violation of a plaintiff's Fourth Amendment rights, and has been rejected by other Courts of Appeals?
    3. Whether, in an action brought under 42 U.S.C. § 1983, an incident giving rise to a reasonable use of force is an intervening, superseding event which breaks the chain of causation from a prior, unlawful entry in violation of the Fourth Amendment?"[4]


    Audio

    • Audio of oral argument:[5]



    Transcript

    • Transcript of oral argument:[6]

    Outcome

    Decision

    Justice Samuel Alito delivered the opinion for a unanimous court. The court struck down a Ninth Circuit rule, known as the provocation rule, because the rule contravened the requirements of the Fourth Amendment. The provocation rule stated that a police officer's otherwise reasonable, lawful defensive use of force was unreasonable as a matter of law if "(1) the officer intentionally or recklessly provoked a violent response and (2) that provocation is an independent constitutional violation." The Supreme Court held that because the rule conflated excessive force claims with other Fourth Amendment claims, the provocation rule permitted excessive force claims that could not succeed as standalone claims under the Fourth Amendment; therefore, the court struck down the rule.[1]

    Opinion

    In his opinion for the court, Justice Alito identified the constitutional tension between the Ninth Circuit's provocation rule and the court's Fourth Amendment jurisprudence. He wrote,[1]

    “

    ...the rule provides a novel and unsupported path to liability in cases in which the use of force was reasonable. Specifically, it instructs courts to look back in time to see if there was a different Fourth Amendment violation that is somehow tied to the eventual use of force. That distinct violation, rather than the forceful seizure itself, may then serve as the foundation of the plaintiff ’s excessive force claim. ...
    This approach mistakenly conflates distinct Fourth Amendment claims. Contrary to this approach, the objective reasonableness analysis must be conducted separately for each search or seizure that is alleged to be unconstitutional. An excessive force claim is a claim that a law enforcement officer carried out an unreasonable seizure through a use of force that was not justified under the relevant circumstances. It is not a claim that an officer used reasonable force after committing a distinct Fourth Amendment violation such as an unreasonable entry.
    By conflating excessive force claims with other Fourth Amendment claims, the provocation rule permits excessive force claims that cannot succeed on their own terms. That is precisely how the rule operated in this case. The District Court found (and the Ninth Circuit did not dispute) that the use of force by the deputies was reasonable ... However, respondents were still able to recover damages because the deputies committed a separate constitutional violation (the warrantless entry into the shack) that in some sense set the table for the use of force. That is wrong. ... To the extent that a plaintiff has other Fourth Amendment claims, they should be analyzed separately.[3]

    		”

    As a result of the court's opinion, the judgment of the Ninth Circuit was vacated and the case was remanded for further proceedings.

    Concurring opinions

    There were no concurring opinions filed in this case.

    Dissenting opinions

    There were no dissenting opinions filed in this case.


    The opinion

    Filings

    The U.S. Supreme Court granted the county's certiorari request on December 2, 2016, limiting argument to questions 1 and 3 of the petition.

    Merits filings

    Parties' briefs

    • Angel Mendez and Jennifer Lynn Garcia, the respondents, filed a merits brief on February 16, 2017.
    • The county filed a reply brief on the merits on March 10, 2017.

    Amicus curiae briefs

    The following groups filed amicus curiae briefs in support of the petitioner, Los Angeles County:

    • Brief of the Major Counties' Sheriffs Association
    • Brief of the National Association of Counties et al.
    • Brief of the United States of America

    The following groups filed amicus curiae briefs in support of the respondents, Angel Mendez and Jennifer Lynn Garcia:

    • Brief of the Georgetown University Law Center chapter of the Black Law Students' Association
    • Brief of the National Police Accountability Project
    • Brief of the Rutherford Institute

    Certiorari filings

    Parties' filings

    • Angel Mendez and Jennifer Lynn Garcia, the respondents, filed a brief in opposition to certiorari on October 24, 2016.

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of the United States, County of Los Angeles, California, et al. v. Mendez et al., decided May 30, 2017
    2. ↑ 2.0 2.1 2.2 2.3 2.4 U.S. Court of Appeals for the Ninth Circuit, Angel Mendez; Jennifer Lynn Garcia v. County of Los Angeles, County of Los Angeles Sheriffs Department, Christopher Conley, and Jennifer Pederson, filed March 2, 2016
    3. ↑ 3.0 3.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    4. ↑ Supreme Court of the United States, Los Angeles County, CA v. Mendez, December 2, 2016
    5. ↑ Supreme Court of the United States, County of Los Angeles v. Mendez, argued March 22, 2017
    6. ↑ Supreme Court of the United States, County of Los Angeles v. Mendez, argued March 22, 2017
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