Graham v. Barnette, No. 19-2512 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's grant of summary judgment to police officers and the city in an action alleging claims arising under 42 U.S.C. 1983 and Minnesota state law after officers entered plaintiff's home without a warrant, seized her, and transported her to a hospital for a mental health evaluation.
The court held that the officers acted reasonably when entering plaintiff's home and affirmed the district court's grant of summary judgment in favor of the officers on plaintiff's warrantless entry claim. In this case, the warrantless search entry was justified by a reasonable belief there was a mental health concern and an emergency requiring attention. Furthermore, once inside the home, the officers did not expand the scope of their search. The court also held that the district court did not err in granting the officers qualified immunity on plaintiff's unreasonable seizure claim, because the probable cause standard was not clearly established and, as a result, a reasonable officer could have believed the decision to arrest plaintiff for an emergency mental health evaluation was lawful.
However, the court now explicitly states that only probable cause that a person poses an emergent danger—that is, one calling for prompt action—to herself or others can tip the scales of the Fourth Amendment's reasonableness balancing test in favor of the government when it arrests an individual for a mental health evaluation because only probable cause constitutes a sufficient "governmental interest" to outweigh a person's "interest in freedom." Finally, the court held that the district court did not err in granting the officers summary judgment on plaintiff's retaliatory arrest claim; the district court correctly entered summary judgment in favor of the city on plaintiff's Monell claims; and the district court did not err by granting summary judgment to the officers on her state-law claims of false imprisonment, battery, assault, and negligence.
Court Description: [Gruender, Author, with Wollman and Kobes, Circuit Judges] Civil Case - Civil Rights. After receiving multiple 911 calls and complaints from Graham and others, police arrived at her home to conduct a welfare check. Officers entered her home, held Graham, escorted her to ambulance and transported her to the hospital, where she was later released. Graham brought civil rights action, alleging unreasonable search and seizure, claims against the City, and state law claims. The district court granted the summary judgment on the basis of qualified immunity in favor of the officers, denied her retaliatory arrest claim, granted immunity on the state law claims and granted summary judgment to the City. The warrantless search entry was justified by a reasonable belief there was a mental health concern and a emergency requiring attention; once inside the home, officers did not expand the scope of their search. With respect to a seizure and whether probable cause is required, only probable cause that a person poses an emergent danger--that is one called for prompt action--to herself or other can tip the scaled of the 4th Amendment's balancing test in favor of the government for arrests for a mental health evaluation. Officers are entitled to qualified immunity here because the law was not clearly established. No reasonable jury could conclude that retaliatory animus was a but-for cause of Graham's arrest. The district court did not err in granting summary judgment to the City on a claim the policy was unconstitutional, as the "reason to believe" in the policy requires probable cause and the need does not have to be imminent. The district court did not err in denying the state law claims.
The court issued a subsequent related opinion or order on July 16, 2021.
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