Los Angeles County, California v. Rettele

127 S.Ct. 1989 (2007)

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Nature of the Case

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Facts

Police (D) obtained a search warrant for two houses where fraud suspects were believed to be found. The police did not know that one of the houses (the first to be searched) had been sold in September to a Max Rettele (P). He moved into it three months earlier with his girlfriend Judy Sadler and Sadler’s 17-year-old son Chase Hall. They were all Caucasians. Watters, the officer in charge, informed his team they would be searching for three African-American suspects, one of whom owned a registered handgun. Around 7:15 am Watters, and six other deputies knocked on the door and announced their presence. Chase Hall answered. The deputies entered the house after ordering Hall to lie face down on the ground. The deputies entered their bedroom with guns drawn and ordered them to get out of their bed and to show their hands. Ps protested that they were not wearing clothes. P stood up and attempted to put on a pair of sweatpants, but deputies told him not to move. Sadler also stood up and attempted, without success, to cover herself with a sheet. P and Sadler were held at gunpoint for one to two minutes before P was allowed to retrieve a robe for Sadler. He was then permitted to dress. P and Sadler left the bedroom within three to four minutes to sit on the couch in the living room. The deputies realized they had made a mistake. They apologized to P and Sadler, thanked them for not becoming upset, and left within five minutes. They proceeded to the other house the warrant authorized them to search, where they found three suspects. Those suspects were arrested and convicted. Ps brought suit under §1983 for violation of their Fourth Amendment rights by obtaining a warrant in reckless fashion and conducting an unreasonable search and detention. The District Court gave summary judgment to Ds. On appeal, Ps did not challenge the validity of the warrant; they did argue that the deputies had conducted the search in an unreasonable manner. A divided panel of the Court of Appeals for the Ninth Circuit reversed.