Law enforcement officers’ encounters with emotionally disturbed people are becoming more prevalent each day. However, case law across the United States has been inconsistent in determining whether law enforcement officers can be held liable when dealing with a person with a mental disability, specifically as to whether the law enforcement officers violated the person’s rights under the Americans with Disabilities Act (ADA). This article analyzes the most recent case that has dealt with this issue in the Ninth Circuit, Sheehan v. City of San Francisco.