In Caniglia v. Strom, decided May 17, 2021, the Supreme Court ruled that there is no such thing as a “community caretaking” exception to the warrant requirement of the Fourth Amendment.
This case began when Mr. Caniglia had an argument with his wife at their Rhode Island home. He then retrieved a pistol from the bedroom and asked his wife to “shoot [him] now and get it over with.” Instead, she left the house and spent the night at a hotel. In the morning, when Mr. Caniglia did not answer his phone, she called the police and asked them to check on him. The police found him on his porch. Mr. Caniglia confirmed his wife’s account of the events of the previous evening, but denied that he was suicidal. The police called an ambulance and eventually convinced him to go to the hospital for a psychiatric evaluation. Later, his wife guided them to two handguns in the house, which they seized.
Mr. Caniglia sued for damages for the violation of his Fourth Amendment rights. The district court granted summary judgment to the officers. The First Circuit affirmed, solely on the ground that the entry of the home and seizure of the guns fell within a “community caretaking exception” to the warrant requirement. Accordingly, the Circuit did not consider the issues of consent by Mr. Caniglia’s wife; whether there were exigent circumstances present; or whether any state law permitted this seizure as part of a mental health intervention.
In a unanimous opinion by Justice Thomas, the Supreme Court reversed. The Court pointed out once again theat the”very core” of the Fourth Amendment is the right to be free of unreasonable police intrusion of one’s own home. There are exceptions, such as a search pursuant to a valid warrant or by consent or when certain exigent circumstances are present, such as the need to render emergency assistance. However, the First Circuit’s “community caretaking rule” “goes beyond anything this Court has recognized.” Although the Court ruled, in Cady v. Dombowski, 413 U.S. 433 (1973), that the police can search an impounded, abandoned, or wrecked car to safeguard the community, “what is reasonable for vehicles is different from what is reasonable for homes.” The Court declined to create a new exception that would justify warrantless searches and seizures in the home.
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