The appeals court affirmed the district court's dismissal of Peller's Federal claims against the individual police officers, who removed her from her home for a psychological evaluation after deciding that she was at risk for suicide, based on some of her statements as well as those of her husband. The court reasoned that considering the totality of the circumstances, the officers had probable cause to believe that Peller suffered from a mental disorder and was a clear and imminent danger to herself. The Fourth Amendment of the U.S. Constitution requires that before an officer can lawfully seize a person for mental evaluation, the officer must have probable cause to believe that the person is suffering from mental illness and that the mental illness makes the person a serious danger to himself/herself or to others. The discussion of procedure after the arrest of a "john" focuses on the kind of evidence officers should have to address the defense of entrapment, such as videotapes and audiotapes. Regarding officer safety, there should be an awareness of surroundings. Also discussed is how the street patrol officer can assist the vice unit and the importance of evaluating each case after the arrest.