Caniglia v. StromCaniglia v. Strom
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.
Syllabus
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 lеft the home and spent the night at a hotel. The next morning, she was unable to reach her husband by phone, so she called the police to request a welfare check. The responding officers accompanied Caniglia‘s wife to the home, where they encountered Caniglia on the porch. The officers called an ambulance based on the belief that Caniglia posed a risk to himself or others. Caniglia agreed to go to the hospital for a psychiatriс evaluation on the condition that the officers not confiscate his firearms. But once Caniglia left, the officers located and seized his weapons. Caniglia sued, claiming that the officers had entered his home and seized him and his firearms without a warrant in violation of the
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
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.
Decades ago, this Court held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the
I
During an argument with his wife at their Rhode Island home, Edward Caniglia (petitioner) retrieved a handgun from the bedroom, put it on the dining room table, and asked his wife to “shoot [him] now and get it over with.” She declinеd, 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.
Petitioner sued, claiming that respondents violated 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 assumed that respondents lacked a warrant or consent, and it expressly disclaimed the possibility that they were reacting to a crime. The court also declined tо consider whether any recognized exigent circumstances were present because respondents had forfeited the point.
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—“‘а 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 with which . . . vehicle[s] can become disabled or involved in . . . accident[s] on public highways” often requires police to perform noncriminal “community caretaking functions,” such as providing aid to motorists. 413 U. S., at 441. But, this recognition that police officers perform many civic tasks in modern society was just that—a recognition that these tasks exist, and not an open-ended license to perform them anywhere.
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What is reasonable for vehicles is different from what is reasonаble 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.
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 quotation marks omitted)). Nothing in today‘s opinion is to the contrary, and I join it on that basis.
I join the оpinion 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 thаt all searches and seizures
3. This case falls within one important category of cases that could be viewed as involving community caretaking: conducting a search or seizure for the purpose of preventing a person from committing suicide. Assuming that petitioner did not voluntarily consent to go with the officers for a psychological assessment,1 he was seized and thus subjected to a serious deprivation of liberty. But was this warrantless seizure “reasonable“? We have addressed the standards required by due process for involuntary commitment to a mental treatment facility, see Addington v. Texas, 441 U. S. 418, 427 (1979); see also O‘Connor v. Donaldson, 422 U. S. 563, 574–576 (1975); Foucha v. Louisiana, 504 U. S. 71, 75–77, 83 (1992), but we have not addressed
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 home for the purpose of ascertaining whether a resident is in urgent nеed 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 seen leaving her home, and she was not answering the phone. Nor сould 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
Petitioner‘s answer was that it would. Indeed, he argued, even if 24 hours went by, the police still could not lawfully enter without a warrant. If the situation remained unchanged for several days, he suggested, the police might be able to enter after obtaining “a warrant for a missing person.” Id., at 9.
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 there is not enough time to get a warrant, seе 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
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.
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., concurring). For examрle, as I will explain, police officers may enter a home without a warrant in circumstances where they are reasonably trying to prevent a potential suicide or to help an elderly person who has been out of contact and may have fallen and suffered a serious injury.
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 explains, any such standalone community caretaking doctrinе 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 open at night.” Livingston, Police, Community Caretaking, and the
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-
A few (non-exhaustive) examples illustrate the point.
Suppose that a woman cаlls 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
Consider another example. Suppose that an elderly man is uncharacteristically absent from Sunday church services
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.