Ryburn v. Huff

A California high-school principal asked four police officers, including Darin Ryburn and Edmundo Zepeda (the officers) (defendants), to investigate a rumor that student Vincent Huff (plaintiff) had threatened a school shooting. After learning that Vincent had been bullied at school and had been absent for two days, the officers decided to interview Vincent. At Vincent’s house, Zepeda knocked on the door and announced the officers’ presence, but no one answered. Ryburn then called Vincent’s mother’s (plaintiff) cell phone and learned that Vincent’s mother and Vincent were inside the house. When Ryburn asked Vincent’s mother to come outside, Vincent’s mother ended the call. Two minutes later, Vincent’s mother and Vincent exited the house. Vincent’s mother refused Ryburn’s request to interview Vincent inside. Ryburn then asked if there were any guns in the house, and Vincent’s mother immediately turned and ran into the house. Ryburn followed Vincent’s mother inside, followed by Vincent and Zepeda. The two remaining officers went inside after watching Ryburn and Zepeda enter because they believed Vincent’s mother had consented to the officers’ entry. Inside, the officers spoke to Vincent and Vincent’s father (plaintiff). The officers ultimately concluded that the rumor about Vincent’s threat was false and reported their findings to the school. The Huffs sued the officers under 42 U.S.C. § 1983, asserting that the officers’ warrantless entry into the Huffs’ home had violated the Huffs’ Fourth Amendment rights. The district court entered judgment for the officers, finding that the officers were entitled to qualified immunity because Vincent’s mother’s odd behavior at the house, combined with what the officers had learned about Vincent’s background, could have led reasonable officers to believe that there could be weapons in the house and that the officers or others could be in imminent danger. The district court said that the officers could not be faulted for their warrantless entry in such a rapidly evolving situation. The Ninth Circuit reversed with respect to Ryburn and Zepeda. The Ninth Circuit held that Vincent’s mother had merely asserted her right to end the conversation with the officers when she went inside, and that any belief that imminent danger existed was objectively unreasonable. The United States Supreme Court granted certiorari.