Bruce v. Guernsey, No. 14-1352 (7th Cir. 2015)
Annotate this CaseBruce’s high-school boyfriend told a school official that Bruce had attempted to kill herself. The official contacted police. Officer Harris went to the home where Bruce was staying and detained her until a sheriff’s deputy, Guernsey, arrived and took Bruce, against her will, to a hospital where she was subjected to a mental health examination. Guernsey said that he had a copy of a physician’s medical examination, but no doctor had examined Bruce, and wrote that Bruce told him that she was thinking of suicide, but Bruce denies making that statement. Harris and Guernsey took no account of her father’s statements contradicting the report and her calm demeanor. Bruce filed suit under 42 U.S.C. 1983, alleging an unreasonable seizure in violation of the Fourth Amendment. The district court held that probable cause for the seizure was apparent on the face of Bruce’s complaint and that Guernsey had arguable probable cause and thus was entitled to qualified immunity. The Seventh Circuit affirmed in favor of Harris, but reversed and remanded as to Guernsey, who overstepped the boundaries of the Fourth Amendment in taking Bruce to the hospital and making false statements that resulted in a more prolonged seizure.
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