Muehler v. Mena

544 U.S. 93 (2005)

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Nature of the Case

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Facts

Ds had reason to believe a gang member lived at 1363 Patricia Avenue and was armed and dangerous related to a drive-by shooting. Their search warrant authorized a broad search of the house for deadly weapons and evidence of gang membership. A SWAT team was used to secure the residence and grounds before the search. P was asleep in her bed when the SWAT team, entered her bedroom and placed her in handcuffs at gunpoint. Three other individuals found on the property were also handcuffed. One or two officers guarded the four detainees, who were allowed to move around a garage but remained in handcuffs. INS officer accompanied the officers executing the warrant. An officer asked for each detainee’s name, date of birth, place of birth, and immigration status. The INS officer later asked the detainees for their immigration documentation. P’s status as a permanent resident was confirmed by her papers. The search found a .22 caliber handgun with .22 caliber ammunition, a box of .25 caliber ammunition, several baseball bats with gang writing, various additional gang paraphernalia, and a bag of marijuana. Before the officers left the area, P was released. P sued Ds alleging that she was detained “for an unreasonable time and in an unreasonable manner” in violation of the Fourth Amendment. Ds moved for summary judgment asserting qualified immunity. That motion was denied. A jury found that Ds violated P’s Fourth Amendment right to be free from unreasonable seizures by detaining her both with force greater than that which was reasonable and for a longer period than that which was reasonable. The jury awarded P $10,000 in actual damages and $20,000 in punitive damages against each D for a total of $60,000. The Court of Appeals affirmed because it was objectively unreasonable to confine her in the converted garage and keep her in handcuffs during the search and that the questioning of P about her immigration status constituted an independent Fourth Amendment violation. The Supreme Court granted certiorari.