In City and County of San Francisco v. Sheehan, 135 S. Ct. 1765 (2015), the United States Supreme Court held that two police officers’ re-entry into the residence of an armed, mentally ill suspect (who had threatened officers moments before with a knife) to quickly subdue her—instead of attempting to accommodate the suspect’s mental illness and extract her through other, non-confrontational means, and thus provoking a second confrontation that caused the officers to shoot the suspect several times—did not violate clearly established law.  The Court held that the officers, who were concerned that the suspect could gather more weapons or try to flee through the back window, did not have “fair and clear warning” that their immediate re-entry violated the Constitution simply because the suspect was mentally ill.