In County of Los Angeles v. Mendez, the justices ruled that an appeals court had used the wrong standard in sustaining a $4 million judgment against two Los Angeles County sheriff’s deputies.
The case arose from a confrontation in 2010. The deputies, searching for a criminal suspect, entered a shack without a warrant while its two occupants were napping. When one of them, Angel Mendez, picked up a BB gun, the deputies shot him and his pregnant companion, Jennifer Garcia. They suffered serious injuries, and part of Mr. Mendez’s right leg was amputated.
The United States Court of Appeals for the Ninth Circuit, in San Francisco, assumed that the use of force by the deputies had been reasonable once they were inside the shack. But the court said the deputies could nonetheless be sued because they had provoked the confrontation by entering the shack without a warrant.
Justice Alito writing for the Supreme Court, rejected that theory. “The rule’s fundamental flaw is that it uses another constitutional violation to manufacture an excessive force claim where one would not otherwise exist,” he wrote.
The Supreme Court's decision does not end the case. It will return to California, where Alito said the other missteps by the officers may provide the couple a path to damages. “For example, if the plaintiffs in this case cannot recover on their excessive force claim, that will not foreclose recovery for injuries proximately caused by the warrantless entry,” Alito wrote.
Justice Neil M. Gorsuch did not participate in this decision.