## Facts

- A high-school principal reported a rumor that student Vincent Huff had written a letter threatening to “shoot up” the school, prompting parental concern and requests for police investigation.
- Officers learned from school interviews that Vincent had been absent for two days, had been bullied, and was viewed by at least one student as capable of carrying out the threat; officers had training on targeted school violence.
- Officers went to the Huff residence; repeated knocking and announcements received no response, though the phone rang inside.
- When an officer reached Mrs. Huff by cell phone and asked to speak, she stated she and Vincent were inside and then abruptly ended the call.
- Mrs. Huff and Vincent later came outside; Vincent reacted skeptically to the officers’ purpose, and Mrs. Huff refused to speak inside the home.
- When asked whether there were guns in the house, Mrs. Huff immediately turned and ran into the home; an officer followed her inside, and other officers entered as well, believing there could be danger.
- Inside, officers briefly spoke with family members, determined there was no shooting threat, and left.
- The Huffs sued under 42 U.S.C. § 1983, alleging the warrantless entry violated the Fourth Amendment.

## Issues

1. Whether the Fourth Amendment permits warrantless home entry when officers reasonably believe an imminent threat of violence exists based on a reported school-shooting threat and occupant conduct at the scene.
2. Whether the officers were entitled to qualified immunity because it was not clearly established that their entry was unconstitutional under the circumstances confronted.

## Decision

- The Supreme Court (per curiam) reversed the Ninth Circuit.
- The Court held the officers were entitled to qualified immunity.
- Reasonable officers could have concluded there was an imminent threat of violence justifying immediate entry.
- Even assuming a Fourth Amendment violation, the unlawfulness of the officers’ conduct was not clearly established.

## Legal Principles

- Warrantless entry into a residence is permissible when officers have a reasonable basis to conclude there is an imminent threat of violence.
- Qualified immunity shields officers unless existing law makes it clear to a reasonable officer that the conduct was unlawful in the situation confronted.
- Courts must assess reasonableness under the totality of circumstances and avoid hindsight-driven, fact-by-fact parsing in rapidly developing situations.

## Conclusion

The Court granted qualified immunity to officers who entered a home without a warrant after investigating a possible school-shooting threat and observing conduct that could reasonably signal immediate danger, concluding that any constitutional violation was not clearly established on those facts.


Ryburn v. Huff, 565 U.S. 469 (2012)