Unanimous Summary Reversal of Reinhardt Ruling

by Ed Whelan

In a unanimous per curiam ruling today in Stanton v. Sims, the Supreme Court summarily reversed a Ninth Circuit ruling written—surprise!—by Judge Stephen Reinhardt.

Reinhardt had held that a police officer, Mike Stanton, was not entitled to qualified immunity on Drendolyn Sims’s claim that he had violated her constitutional rights by entering her yard (and inadvertently injuring her) in pursuit of a suspect, Nicholas Patrick. As the Court sums up his holding, Reinhardt “found the law to be clearly established”—that’s the standard that must be met to deny qualified immunity—“that Stanton’s pursuit of Patrick did not justify his warrantless entry, given that Patrick was suspected of only a misdemeanor.”

So what was the actual state of this supposedly “clearly established” body of law? Here’s the Court’s summary (following its more detailed discussion):

Two opinions of this Court were equivocal on the lawfulness of his entry; two opinions of the State Court of Appeal affirmatively authorized that entry; the most relevant opinion of the Ninth Circuit was readily distinguishable; two Federal District Courts in the Ninth Circuit had granted qualified immunity in the wake of that opinion; and the federal and state courts of last resort around the Nation were sharply divided.

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