CANIGLIA v. STROM ET AL.
No. 20-157
SUPREME COURT OF THE UNITED STATES
May 17, 2021
593 U. S. ____ (2021)
THOMAS, J.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT; Arguеd March 24, 2021
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
CANIGLIA v. STROM ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT
No. 20-157. Argued March 24, 2021—Decided May 17, 2021
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
Held: Neither the holding nor logic of Cady justifies such warrantless searches and seizures in the home. Cady held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment. In reaching this conclusion, the Court noted that the officers who patrol the “public highways” are often called to discharge noncriminal “community caretaking functions,” such as responding to disabled vehicles or investigating accidents. 413 U. S., at 441. But searches of vehicles and homes are constitutionally different, as thе Cady opinion repeatedly stressed. Id., at 439, 440-442. The very core of the Fourth Amendment‘s guarantee is the right of a person to retreat into his or her home and “there be free from unreasonable governmental intrusion.” Florida v. Jardines, 569 U. S. 1, 6. A recognition of the existence of “community caretaking” tasks, like rendering aid to motorists in disabled vehicles, is not an open-ended license to perform them anywhere. Pp. 3-4.
953 F. 3d 112, vacated and remanded.
THOMAS, J., delivered the opinion for a unanimous Court. ROBERTS, C. J., filed a concurring opinion, in which BREYER, J., joined. ALITO, J., and KAVANAUGH, J., filed concurring opinions.
Opinion of the Court
NOTICE: This opinion is subject to formal revision before publication in the preliminary print of the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, of any typographical or other formal errors, in order that corrections may be made before the preliminary print goes to press.
SUPREME COURT OF THE UNITED STATES
No. 20-157
EDWARD A. CANIGLIA, PETITIONER v. ROBERT F. STROM, ET AL.
ON WRIT
[May 17, 2021]
JUSTICE THOMAS delivered the opinion of the Court.
Decades ago, this Court held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment. Cady v. Dombrowski, 413 U. S. 433 (1973). In reaching this conclusion, the Court observed that police officers who patrol the “public highways” are often called to discharge noncriminal “community caretaking functions,” such as responding to disabled vehicles or investigating accidents. Id., at 441. The question today is whether Cady‘s acknowledgment of these “caretaking” duties creates a standalone doctrine that justifies warrantless searches and seizures in the home. It does not.
I
During an argument with his wife at their Rhode Island home, Edward Caniglia (petitioner) retrieved a hаndgun from the bedroom, put it on the dining room table, and asked his wife to “shoot [him] now and get it over with.” She declined, and instead left to spend the night at a hotel. The next morning, when petitioner‘s wife discovered that she could not reach him by telephone, she called the police (respondents) to request a welfare check.
Opinion of the Court
Respondents accompanied petitioner‘s wife to the home, where they encountered petitioner on the porch. Petitioner spoke with respondents and confirmed his wife‘s account of the argument, but denied that he was suicidal. Respondents, however, thought that petitioner posed a risk to himself or others. They called an ambulance, and petitioner agreed to go to the hospital for a psychiatric evaluation—but only after respondents allegedly promised not to confiscate his firearms. Once the ambulance had taken petitioner away, however, respondents seized the weapons. Guided by рetitioner‘s wife—whom they allegedly misinformed about his wishes—respondents entered the home and took two handguns.
Petitioner sued, claiming that respondents violated the Fourth Amendment when they entered his home and seized him and his firearms without a warrant. The District Court granted summary judgment to respondents, and the First Circuit affirmed solely on the ground that the decision to remove petitioner and his firearms from the premises fell within a “community caretaking exception” to the warrant requirement. 953 F. 3d 112, 121-123, 131 and nn. 5, 9 (2020). Citing this Court‘s statement in Cady that police officers often have noncriminal reasons to interact with motorists on “public highways,” 413 U. S., at 441, the First Circuit extrapolated a freestanding community-caretaking exception that applies to both cars and homes. 953 F. 3d, at 124 (“Threats to individual and community safety are not confined to the
II
The
To be sure, the
The First Circuit‘s “community caretaking” rule, however, goes beyond anything this Court has recognized. The decision below аssumed that respondents lacked a warrant or consent, and it expressly disclaimed the possibility that they were reacting to a crime. The court also declined to consider whether any recognized exigent circumstances were present because respondents had forfeited the point. Nor did it find that respondents’ actions were akin to what a private citizen might have had authority to do if petitioner‘s wife had approached a neighbor for assistance insteаd of the police.
Neither the holding nor logic of Cady justified that approach. True, Cady also involved a warrantless search for a firearm. But the location of that search was an impounded vehicle—not a home—“a constitutional difference” that the opinion repeatedly stressed. 413 U. S., at 439; see also id., at 440-442. In fact, Cady expressly contrasted its treatment of a vehicle already under police control with a search of a car “parked adjacent to the dwelling place of the owner.” Id., at 446-448 (citing Coolidge v. New Hampshire, 403 U. S. 443 (1971)).
Cady‘s unmistakable distinction between vehicles and homes also places into proper context its reference to “community caretaking.” This quote comes from a portion of the opinion explaining that the “frequency
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What is reasonable for vehicles is different from what is reasonable for homes. Cady acknowledged as much, and this Court has repeatedly “declined to expand the scope of . . . exceptions to the warrant requirement to permit warrantless entry into the home.” Collins, 584 U. S., at ____ (slip op., at 8). We thus vacate the judgment below and remand for further proceedings consistent with this opinion.
It is so ordered.
ROBERTS, C. J., concurring
SUPREME COURT OF THE UNITED STATES
No. 20-157
EDWARD A. CANIGLIA, PETITIONER v. ROBERT F. STROM, ET AL.
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT
[May 17, 2021]
CHIEF JUSTICE ROBERTS, with whom JUSTICE BREYER joins, concurring.
Fifteen years ago, this Court unanimously recognized that “[t]he role of a peace officer includes preventing violence and restoring order, not simply rendering first aid to casualties.” Brigham City v. Stuart, 547 U. S. 398, 406 (2006). A warrant to enter a home is not required, we explained, when there is a “need to assist persons who are seriously injured or threatened with such injury.” Id., at 403; see also Michigan v. Fisher, 558 U. S. 45, 49 (2009) (per curiam) (warrantless entry justified where “there was an objectively reasonable basis for believing that medical assistance was needed, or persons were in danger” (internal quоtation marks omitted)). Nothing in today‘s opinion is to the contrary, and I join it on that basis.
ALITO, J., concurring
SUPREME COURT OF THE UNITED STATES
No. 20-157
EDWARD A. CANIGLIA, PETITIONER v. ROBERT F. STROM, ET AL.
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT
[May 17, 2021]
JUSTICE ALITO, concurring.
I join the opinion of the Court but write separately to explain my understanding of the Court‘s holding and to highlight some important questions that the Court does not decide.
1. The Court holds—and I entirely agree—that there is no special
The Court‘s decision in Cady v. Dombrowski, 413 U. S. 433 (1973), did not recognize any such “freestanding”
2. While there is no overarching “community caretaking” doctrine, it does not follow that all searches and seizures conducted for non-law-enforcement purposes must be analyzed under precisely the same
call features of these laws into question. The Court appropriately refrains from doing so.
4. This case also implicates another body of law that petitioner glossed over: the so-called “red flag” laws that some States are now enacting. These laws enable the police to seize guns pursuant to a court order to prevent their use for suicide or the infliction of harm on innocent persons. See, e.g.,
5. One additional category of cases should be noted: those involving warrantless, nonconsensual searches of a hоme for the purpose of ascertaining whether a resident is in urgent need of medical attention and cannot summon help. At oral argument, THE CHIEF JUSTICE posed a question that highlighted this problem. He imagined a situation in which neighbors of an elderly woman call the police and express concern because the woman had agreed to come over for dinner at 6 p.m., but by 8 p.m., had not appeared or called even though she was never late for anything. The woman had not been seеn leaving her home, and she was not answering the phone. Nor could the neighbors reach her relatives by phone. If the police entered the home without a warrant to see if she needed help, would that violate the
THE CHIEF JUSTICE‘s question concerns an important real-world problem. Today, more than ever, many people, including many elderly persons, live alone.3 Many elderly men and women fall in their homes,4 or become incapacitated for other reasons, and unfortunately, there are many cases in which such persons cannot call for assistance. In those cases, the chances for a good recovery may fade with each passing hour.5 So in THE CHIEF JUSTICE‘s imaginary case, if the elderly woman was seriously hurt or sick and the pоlice heeded petitioner‘s suggestion about what the
Our current precedents do not address situations like this. We have held that the police may enter a home without a warrant when there are “exigent circumstances.” Payton v. New York, 445 U. S. 573, 590 (1980). But circumstances are exigent only when thеre is not enough time to get a warrant, see Missouri v. McNeely, 569 U. S. 141, 149 (2013); Michigan v. Tyler, 436 U. S. 499, 509 (1978), and warrants are not typically granted for the purpose of checking on a person‘s medical condition. Perhaps States should institute procedures for the issuance of such warrants, but
in the meantime, courts may be required to grapple with the basic
6. The three categories of cases discussed above are simply illustrative. Searches and seizures conducted for other non-law-enforcement purposes may arise and may present their own
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In sum, the Court properly rejects the broad “community caretaking” theory on which the decision below was based. The Court‘s decision goes no further, and on that understanding, I join the opinion in full.
KAVANAUGH, J., concurring
SUPREME COURT OF THE UNITED STATES
No. 20-157
EDWARD A. CANIGLIA, PETITIONER v. ROBERT F. STROM, ET AL.
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT
[May 17, 2021]
JUSTICE KAVANAUGH, concurring.
I join the Court‘s opinion in full. I write separately to underscore and elaborate on THE CHIEF JUSTICE‘s point that the Court‘s decision does not prevent police officers from taking reasonable steps to assist those who are inside a home and in need of aid. See ante, at 1 (ROBERTS, C. J., сoncurring). For example, as I will
Ratified in 1791 and made applicable to the States in 1868, the
Over the years, many courts, like the First Circuit in this case, have relied on what they have labeled a “community caretaking” doctrine to allow warrantless entries into the home for a non-investigatory purpose, such as to prevent a suicide or to conduct a welfare check on an older individual who has been out of contact. But as the Court today exрlains, any such standalone community caretaking doctrine was primarily devised for searches of cars, not homes. Ante, at 3-4; see Cady v. Dombrowski, 413 U. S. 433, 447-448 (1973).
That said, this
This case does not require us to explore all the contours of the exigent circumstances doctrine as applied to emergency-aid situations because the officers here disclaimed reliance on that doctrine. But to avoid any confusion going forward, I think it important to briefly describe how the doctrine applies to some heartland emergency-aid situations.
As Chief Judge Livingston has cogently explained, although this doctrinal area does not draw much attention from courts or scholars, “municipal police spend a good deal of time responding to calls about missing persons, sick neighbors, and premises left оpen at night.” Livingston, Police, Community Caretaking, and the Fourth Amendment, 1998 U. Chi. Leg. Forum 261, 263 (1998). And as she aptly noted, “the responsibility of police officers to search for missing persons, to mediate disputes, and to aid the ill or injured has never been the subject of serious debate; nor has” the “responsibility of police to provide services in an emergency.” Id., at 302.
Consistent with that reality, the 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 reason- able to act now. See, e.g., Sheehan, 575 U. S., at 612; Michigan v. Fisher, 558 U. S., at 48-49; Brigham City, 547 U. S., at 406-407. The officers do not need to show that the harm has already occurred or is mere moments away, because knowing that will often be difficult if not impossible in cases involving, for example, a person who is currently suicidal or an elderly person who has been out of contact and may have fallen. If someone is at risk of serious harm and it is reasonable fоr officers to intervene now, that is enough for the officers to enter.
A few (non-exhaustive) examples illustrate the point.
Suppose that a woman calls a healthcare hotline or 911 and says that she is contemplating suicide, that she has firearms in her home, and that she might as well die. The operator alerts the police, and two officers respond by driving to the woman‘s home. They knock on the door but do not receive a response. May the officers enter the home? Of course.
The exigent circumstances doctrine applies because the officers have an “objectively reasonable basis” for believing that an occupant is “seriously injured or threatened with such injury.” Id., at 400, 403; cf. Sheehan, 575 U. S., at 612 (officers could enter the room of a mentally ill person who had locked herself inside with a knife). After all, a suicidal individual in such a scenario could kill herself at any moment. The
and repeatedly fails to answer his phone throughout the day and night. A concerned relative calls the police and asks the officers to perform a wellness check. Two officers drive to the man‘s home. They knock but receive no response. May the officers enter the home? Of course.
Again, the officers have an “objectively reasonable basis” for believing that an occupant is “seriously injured or threatened with such injury.” Brigham City, 547 U. S., at 400, 403. Among other possibilities, the elderly man may have fallen and hurt himself, a common cause of death or serious injury for older individuals. The
To be sure, courts, police departments, and police officers alike must take care that officers’ actions in those kinds of cases are reasonable under the circumstances. But both of those examples and others as well, such as cases involving unattended young children inside a home, illustrate the kinds of warrantless entries that are perfectly constitutional under the exigent circumstances doctrine, in my view.
With those observations, I join the Court‘s opinion in full.