Castagna v. Jean, 955 F.3d 211

On March 17, 2013, Christopher and Gavin Castagna hosted a large St. Patrick’s Day party in Christopher’s first-floor apartment; the front door was open and many guests appeared intoxicated, some looking underage.
Neighbors called 911 for a loud party; a seven-officer unit (including Edwards, Jean, Kaplan) reassigned for holiday duties responded and observed noise, open door, and people coming and going.
Officers announced themselves, received no immediate response from inside, and entered through the open door to locate the homeowners, lower the music, and check on potentially underage or intoxicated guests' safety (a claimed community caretaking function).
Inside, officers proceeded toward the back/bedroom; after Jean knocked and Christopher opened a bedroom door, Christopher pushed and slammed the door on Jean’s foot, leading to escalation and arrests.
At trial a jury found for all defendants on all counts; the district court nonetheless granted the Castagnas’ motion for a new trial, then amended judgment to hold the three officers liable on the § 1983 unlawful-entry claim and awarded nominal damages; the officers appealed.

Issue	Castagna(s)' Argument	Officers' Argument	Held
Whether entry through open front door was an unreasonable, warrantless home entry	Entry was unlawful because it was a warrantless intrusion into the home not justified by any exception	Entry was lawful under the community caretaking exception (and/or exigent/emergency-aid) to the warrant requirement	Entry was constitutional under the community caretaking exception; no Fourth Amendment violation
Whether the officers are entitled to qualified immunity for the entry	Qualified immunity should be denied because officers violated clearly established law	Qualified immunity applies because (1) entry was lawful and (2) law was not clearly established in 2013	Officers entitled to qualified immunity; judgment for plaintiffs should be reversed
Whether the law in 2013 clearly established that community caretaking could not justify home entry	Law was sufficiently settled to put officers on notice that home entry was unlawful	No clear consensus barred application to homes in 2013; mixed circuit authority made the law uncertain	Law was not clearly established in 2013; qualified immunity applies
Whether remaining in the apartment after music was turned off and advancing toward the bedroom created a separate Fourth Amendment violation	Remaining and advancing toward bedroom was a separate, post-entry violation	Claim is waived and was not preserved as an independent claim on appeal	Argument waived; court will not treat bedroom entry as independent on appeal

Cady v. Dombrowski, 413 U.S. 433 (1973) (articulates community caretaking exception to warrant requirement)
Caniglia v. Strom, 953 F.3d 112 (1st Cir. 2020) (applies community caretaking exception to home entries and sets reasonableness balancing framework)
Rodriguez-Morales v. United States, 929 F.2d 780 (1st Cir. 1991) (describes community caretaking functions and reasonableness standard)
MacDonald v. Town of Eastham, 745 F.3d 8 (1st Cir. 2014) (concludes community-caretaking boundaries were not clearly established in earlier years)
Eves v. LePage, 927 F.3d 575 (1st Cir. 2019) (en banc) (sets qualified-immunity framework used by the court)
White v. Pauly, 137 S. Ct. 548 (2017) (qualified immunity protects all but the plainly incompetent or those who knowingly violate the law)
Payton v. New York, 445 U.S. 573 (1980) (warrantless home entries are presumptively unreasonable)
Lockhart-Bembery v. Sauro, 498 F.3d 69 (1st Cir. 2007) (no requirement officers use least intrusive means for community caretaking)
United States v. Rohrig, 98 F.3d 1506 (6th Cir. 1996) (applies community caretaking rationale to home entry after a noise complaint)
United States v. Quezada, 448 F.3d 1005 (8th Cir. 2006) (upholds entry where officer reasonably feared occupant unable to respond and announced presence)