Caniglia v. Strom: Community caretaking doctrine does not apply to searches of residences
There is no “community caretaking” doctrine that permits police to conduct warrantless searches and seizures in a home, the U.S. Supreme Court held May 27 in Caniglia v. Strom.
Police were called to Edward Caniglia’s home because he was reported to be suicidal. A family member asked police to conduct a wellness check.
When police arrived, they thought Caniglia might be a threat to himself or others. Police called an ambulance, and Caniglia agreed to go to the hospital for a psychiatric evaluation.
After the ambulance took Caniglia away, police entered his home and seized two handguns.
Caniglia sued, claiming police violated the Fourth Amendment when they entered his home and seized his guns without a warrant.
The District Court granted summary judgment for the police.
The First Circuit affirmed on grounds that the decision to enter the house and seize the guns fell within the “community caretaking exception” to the warrant requirement.
The Supreme Court reversed, in a unanimous 9-0 opinion.
The Court recognized that it has applied a “community caretaking exception” to warrantless searches of impounded vehicles and to contexts such as responding to disabled vehicles and accidents.
“The First Circuit’s ‘community caretaking’ rule, however, goes beyond anything this Court has recognized,” the Court said.
The Fourth Amendment authorizes entry into homes pursuant to a valid warrant, and when exigent circumstances exist, including the need to render emergency assistance to an injured occupant or to protect an occupant from imminent injury, the Court said.
But the Court has drawn an “unmistakable distinction between vehicles and homes,” the Court said. “What is reasonable for vehicles is different from what is reasonable for homes.”
“This Court has repeatedly ‘declined to expand the scope of … exceptions to the warrant requirement to permit warrantless entry into the home,’” the Court concluded.
Several justices wrote concurrences to emphasize that nothing in the opinion prevents police from entering a home under exigent circumstances when needed to help a person with serious injury or threatened with serious injury.
They emphasized that more people are living alone, including many elderly people. They said police can take reasonable steps to check on and assist those people.
“[T]he Court’s exigency precedents, as I read them, permit warrantless entries when police officers have an objectively reasonable basis to believe that there is a current, ongoing crisis for which it is reasonable to act now,” Justice Kavanaugh said.