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Name: Mena v. City of Simi Valley
Court: US Court of Appeals
District 9 Cir
Opinion Date: 09/22/2000
Subsequent History: None

Police officers for the city of Simi Valley executed a search on the Mena’s residence based on a warrant which was later determined by the district court to be overbroad. The warrant had authorized the search of the entire residence, even though the house was a multi-unit dwelling, and the probable cause related only to one residential unit and possibly the common areas. The Menas filed suit under 42 U.S.C. § 1983, which alleged that the officers had violated their civil rights by obtaining an overbroad search warrant, executing an overbroad search, unlawfully detaining Mrs. Mena during the search, conducting the search in an unreasonable manner, and failing to comply with “knock-notice” requirements. The defendants claimed that they were entitled to immunity, and moved for summary judgment. This appeal was from the denial of the summary judgment motion. The appellate court here held that the warrant was not overbroad because there was no evidence the officers knew the building was a multi-unit dwelling, and could therefore reasonably have believed that there was probable cause to search the entire premises. As a matter of law, they were entitled to qualified immunity with regard to that claim, and the summary judgment motion should have been granted. However, Mrs. Mena was removed from her bed, handcuffed, and brought into the garage, where she was forced to remain for three hours, even after officers discovered that the Mena’s house was a separate dwelling. Based on the totality of circumstances, a jury could reasonably conclude that the detention of Mrs. Mena went past the point of a proper search, and therefore that issue should be decided by a trier of fact. Further, because officers unnecessarily broke down two unlocked doors, summary judgment was properly denied on the claim of conducting the search in an unreasonable manner. Finally, there was also a triable issue of fact regarding where police had “knocked and announced” before entering, and therefore the summary judgment motion on that issue was also properly denied.