Case Explained: REHN V. CITY OF SEATTLE, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-18 Docket: 2:23-cv-01609-RAJ The Ninth Circuit reversed the district court’s denial of qualified immunity to the City of Seattle and its police officers, holding that the officers were entitled to qualified immunity despite the plaintiff’s claims of an unreasonable search and seizure. The court applied the standard that officials are not liable unless they violated clearly established statutory or constitutional rights of which a reasonable person would have known. While assuming for the sake of argument that the warrantless entry into the wrong apartment and the display of weapons could constitute Fourth Amendment violations, the court found that the unlawfulness of these specific actions was not clearly established at the time. Regarding the warrantless entry, the court applied the rule from *Maryland v. Garrison* that a search is constitutional if the officer’s mistake regarding the location is “objectively understandable and reasonable.” The court determined that existing precedent did not create a “robust consensus” establishing that such a mistaken entry in these specific circumstances was unlawful. The court distinguished the cases relied upon by the district court, noting they involved different factual contexts, such as the absence of exigent circumstances or the execution of a search warrant for a nearby house, whereas here officers were responding to exigent circumstances involving reports of domestic disputes, suicidal ideation, and weapons. Regarding the excessive force claim involving weapons drawn, the court found that pointing a firearm in a resident’s direction for only a few seconds during an initial sweep did not clearly establish a violation of the Fourth Amendment. The court distinguished prior Ninth Circuit decisions like *Thompson v. Rahr* and *Motley v. Parks*, which involved more egregious conduct such as pointing a loaded gun at a compliant suspect’s head or training a weapon on an infant. Furthermore, the court noted that body-worn-camera footage showed the officers held their weapons in a low-ready position and never pointed or raised them directly at the plaintiff. The practical consequence of this decision is that the case is remanded to the district court with instructions to enter judgment in favor of the defendants on qualified immunity grounds, effectively dismissing the claims against the City and the individual officers. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.