Caniglia v. Strom - 141 S. Ct. 1596 (2021)

Rule:

The Fourth Amendment protects the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures. The very core of this guarantee is the right of a man to retreat into his own home and there be free from unreasonable governmental intrusion. To be sure, the Fourth Amendment does not prohibit all unwelcome intrusions on private property—only “unreasonable” ones. The U.S. Supreme Court has thus recognized a few permissible invasions of the home and its curtilage. The Court has also held that law enforcement officers may enter private property without a warrant when certain exigent circumstances exist, including the need to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.

Facts:

During an argument with his wife, petitioner Edward Caniglia placed a handgun on the dining room table and asked his wife to “shoot [him] and get it over with.” His wife instead left the home and spent the night at a hotel. The next morning, she was unable to reach her husband by phone, so she called the police to request a welfare check. The responding officers accompanied Caniglia's wife to the home, where they encountered Caniglia on the porch. The officers called an ambulance based on the belief that Caniglia posed a risk to himself or others. Caniglia agreed to go to the hospital for a psychiatric evaluation on the condition that the officers not confiscate his firearms. But once Caniglia left, the officers located and seized his weapons. Caniglia sued, claiming that the officers had entered his home and seized him and his firearms without a warrant in violation of the Fourth Amendment. The District Court granted summary judgment to the officers. The First Circuit affirmed, extrapolating from the Court's decision in Cady v. Dombrowski, 413 U. S. 433, 93 S. Ct. 2523, 37 L. Ed. 2d 706, a theory that the officers' removal of Caniglia and his firearms from his home was justified by a “community caretaking exception” to the warrant requirement.

Issue:

Did Cady’s acknowledgment of “caretaking” duties create a standalone doctrine that justifies warrantless searches and seizures in the home?

Answer:

No.

Conclusion:

The Supreme Court held that the U.S. Court of Appeals for the First Circuit erred in finding that the decision to remove Caniglia’s firearms from his home without a warrant fell within a community caretaking exception, extrapolating from Cady v. Dombrowski a freestanding community-caretaking exception that applied to both cars and homes, because what was reasonable for vehicles was different from what was reasonable for homes.