In a unanimous opinion delivered Monday, the Supreme Court ruled against police officers who entered a Rhode Island man’s home and seized two of his firearms without a warrant.
“What is reasonable for vehicles is different from what is reasonable for homes,” Associate Justice Clarence Thomas wrote in the court’s majority opinion.
“The question today is whether Cady’s acknowledgment of these ‘caretaking’ duties creates a standalone doctrine that justices warrantless searches and seizures in the home. It does not.”
In 2015, the case began shortly after Edward and Kim Caniglia got into a heated argument in which Mr. Caniglia placed his handgun on the kitchen table and asked his wife to “shoot [him] and get it over with.” Afterward, Mrs. Caniglia left to stay at a hotel for the night.
The next morning she failed to reach her husband by phone, so Mrs. Caniglia called the Cranston Police Department to conduct a wellness check. The police arrived and met Mr. Caniglia unharmed outside of his house, awaiting their arrival.
Mr. Caniglia told the police that his mental health “was none of their business,” and denied that he was suicidal. After speaking with the plaintiff, the officers deemed that he “appeared normal.” The officers, however, deemed Mr. Caniglia a threat to himself or others, and requested that he go to the hospital for a psychiatric evaluation.
Mr. Caniglia consented to the evaluation on the condition that his firearms would not be confiscated. Once he left in the ambulance, the officers — who also allegedly deceived his wife — entered their residence and seized his firearms. He filed a civil rights lawsuit claiming that the officers violated the Fourth Amendment’s warrant requirement.
After the District Court filed summary judgment in favor of the officers, the First Circuit affirmed their decision, citing the “community caretaker” doctrine devised in the 1973 court case Cady v. Dombrowski, which allowed officers to search impounded cars and remove highway debris.
The court’s unanimous decision rejected the First Circuit’s broad interpretation of the “caretaker exception,” holding that “neither the holding nor the logic” justified the police’s warrantless search and seizure, the associate justice wrote.
The Supreme Court maintained that police officers “perform many civic tasks in modern society,” but mere acknowledgment of these tasks does not grant “an open-ended license to perform them anywhere.”
Chief Justice Roberts, consigned by associate Justice Steven Breyer, wrote a concurring opinion expressing the idea that “a warrant to enter a home is not required” when a “need to assist” people are injured or under bodily threat.
Associate Justices Samuel Alito and Brett Kavanaugh also filed concurrent opinions, mirroring the Chief Justices’ concerns that police officers should be permitted to enter a residence to proffer aid to the elderly and injured without a warrant.
“The Fourth Amendment does not prevent the officers from entering the home and checking on the man’s well-being,” Kavanaugh said in his concurring opinion.
The court’s unanimous decision did not address state “red flag” laws, which enable police officers to seize firearms pursuant to a court order. Moreover, the opinion also set the boundaries between other circumstances in which law enforcement action may challenge certain protections afforded under the Fourth Amendment.
But the court’s opinions reaffirmed that there is “no special Fourth Amendment rule” that exists under a broad category of “community caretaking,” according to Alito.
Following the holding, the First Circuit’s broad interpretation of the “community caretaker” theory received criticism from nearly every corner of the political spectrum — a rare sight for today.
The American Civil Liberties Union, as well as the American Conservative Union Foundation, the Cato Institute and a chorus of Second Amendment advocates filed coordinated amicus briefs urging the high court to “reject a broader standard that would give police free rein to enter the home without probable cause or a warrant,” the brief said.
The ACLU, as well as the Gun Owners of America, released Twitter threads celebrating the ruling Monday.
In some good news, the Supreme Court rejected the government’s scarily broad “community caretaking” argument in Caniglia v. Strom.
If the government had won, then law enforcement would have had free rein to break into a person’s home with no warrant and no probable cause.
— ACLU (@ACLU) May 17, 2021
VICTORY: This morning the Supreme Court issued its decision in Caniglia v. Strom and struck down an attempt by @CranstonPolice to conduct warrantless searches for guns in a home using the so-called “community caretaking function.”💪
— Gun Owners of America (@GunOwners) May 17, 2021
Caniglia v. Strom was one of four decisions released by the court Monday — and one of the few on the court’s docket this year that touches on a constitutional question.
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