Chief’s Counsel: Ryburn v. Huff Affirms Police Decisions in Warrantless Entries

On January 23, 2012, the U.S. Supreme Court issued its headline grabbing opinion in U.S. v. Jones,1 requiring, under the Fourth Amendment, that law enforcement officers obtain search warrants to place and track electronic global positioning system (GPS) tracking devices on vehicles. That very same day, amid the debate stemming from the Jones case, the Supreme Court quietly issued its opinion in Ryburn v. Huff.2 The court’s holding seemed expected to some: Officers are protected by qualified immunity after making a warrantless entry into a home without the permission of the occupants based on concerns of imminent threat of injury.3 Notwithstanding the attention to U.S. v. Jones, Ryburn v. Huff may be the most important case out of this term of the Supreme Court for law enforcement. Ryburn strengthens the court’s reliance on the officer’s knowledge and decision making in rapidly evolving, dynamic incidents.