On May 18, 2015, the U.S. Supreme Court issued its decision in City and County of San Francisco v. Sheehan. Law enforcement practitioners had awaited this decision, as it appeared the case would address the question of whether the Americans with Disabilities Act (ADA) requires arresting officers to provide reasonable accommodations to a disabled person before taking police action.1 The U.S. Supreme Court did not answer this question; however, it did provide an opinion that further elucidates the qualified immunity defense.