In the case of Stanton v. Sims, the US Supreme Court ruled in favor of a police officer who was sued for excessive force after he kicked down a fence while pursuing a suspect into private property without a warrant. The court held that under California law, officers are allowed to enter private property when they believe someone has committed or is about to commit an offense. In this case, Officer Mike Stanton had been chasing Nicholas Patrick Sims and believed him to be potentially dangerous due to his erratic behavior and refusal to stop when ordered by police. When Sims ran onto private property behind a gate taller than six feet high, Stanton kicked it open fearing that if he lost sight of Sims it could put himself or others in danger. This resulted in injury for Drendolyn Sims (no relation), who was standing behind the gate at the time; she subsequently filed suit against Officer Stanton claiming violation of her Fourth Amendment rights against unreasonable searches and seizures.

In the dissenting opinion for Stanton v. Sims, Justice Sonia Sotomayor argued that the majority's decision to grant qualified immunity to a police officer who entered a private property without warrant was incorrect and set a dangerous precedent. She contended that it is not always reasonable for an officer to assume they have an implicit invitation to enter someone's home or yard without explicit permission or exigent circumstances. The justice also expressed concern about the potential erosion of Fourth Amendment rights, which protect citizens from unreasonable searches and seizures by law enforcement officers. Furthermore, she criticized the court’s failure in providing clear guidance on when exactly such warrantless entries are justified under community caretaking functions.