Corrigan v. District of Columbia
841 F.3d 1022
D.C. Cir.2016Background
- MPD responded to a mistaken suicide-hotline call from Matthew Corrigan (Army reservist with PTSD) and were told he owned guns and had IED training; a neighbor/ex-girlfriend referenced a green duffel with unspecified “military items.”
- Officers arrived, reported a smell of gas (gas was turned off), evacuated neighbors, and established a barricade; Corrigan was contacted, exited, and peacefully surrendered; he refused to give his key or consent to search.
- The ERT (Emergency Response Team) conducted an initial warrantless sweep of the home and found no persons or dangerous items in plain view.
- Several hours later, pursuant to Lieutenant Glover’s order, the EOD (Explosive Ordnance Disposal) re-entered and performed a top-to-bottom, intrusive search (opening locked boxes and bags) and seized firearms, a military smoke grenade, and related items.
- The Superior Court suppressed the seized items and the District nolle prossed charges; Corrigan sued under 42 U.S.C. § 1983; the district court granted summary judgment for defendants, and the D.C. Circuit reversed in part.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the EOD’s second, intrusive search without a warrant violated the Fourth Amendment | Corrigan: no objectively reasonable exigency or emergency justification existed for a second break-in and broad search after the initial sweep and his surrender | MPD: exigent circumstances / emergency-aid (public safety) and community-caretaking justified the warrantless re-entry and full search | Held: The EOD search violated the Fourth Amendment — no objective basis for continued exigency and the search was not narrowly tailored |
| Whether the initial ERT protective sweep was constitutional | Corrigan: sweep was unnecessary and invasive | MPD: limited sweep to search for injured/other persons was reasonable given ambiguous reports about an ex-girlfriend and Corrigan’s initial deception | Held: The limited ERT sweep was potentially justified; officers entitled to qualified immunity for that sweep |
| Whether officers are entitled to qualified immunity for the EOD search | Corrigan: law clearly established that a warrantless home search requires an objectively reasonable basis for exigency; no reasonable officer could conclude exigency persisted | MPD: split-second/emergency standards and precedent (and reliance on initial information) shield officers | Held: Qualified immunity denied for the EOD officers as to the second search — the violation was of clearly established law; remand limited issues (e.g., reliance on supervisor) to district court |
| Whether municipal (Monell) liability should proceed | Corrigan: District liable for policies/customs that caused the violation | District: summary judgment precluded municipal liability | Held: Remanded municipal-liability claim for district court to decide in first instance |
Key Cases Cited
- Payton v. New York, 445 U.S. 573 (warrantless home entry presumptively unreasonable)
- Brigham City v. Stuart, 547 U.S. 398 (emergency aid is a type of exigent circumstance; officers need an objectively reasonable basis)
- Mincey v. Arizona, 437 U.S. 385 (warrantless searches in homes must be strictly circumscribed by the exigency)
- Cady v. Dombrowski, 413 U.S. 433 (community caretaking doctrine origin; applied to vehicles)
- Kentucky v. King, 563 U.S. 452 (exigent-circumstances framework; warrants and urgency)
- Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established law standard for qualified immunity)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-step and courts may address either prong)
- Mora v. City of Gaithersburg, 519 F.3d 216 (4th Cir.) (exigent search upheld where caller reported suicidal threats plus weapons and corroboration)
- United States v. Dawkins, 17 F.3d 399 (D.C. Cir.) (exigent-circumstances analysis under totality of circumstances and required level of cause)