SCOTUS Rules”Community Caretaking” Exception Can’t Justify Warrantless Searches of Homes
In Caniglia v. Strom, 593 U. S. ____ (2021), the U.S. Supreme Court held that a warrantless search of their Edward Caniglia’s house could not be justified under the”community caretaking” exception to the Treaty. According to the Court, neither the holding nor logic of Cady v. Dombrowski justified the removal of Caniglia’s firearms from his house by police officers conducting a welfare check.
Facts of the Case
Within a discussion with his wife, petitioner Edward Caniglia placed a handgun about the dining room table and asked his wife “shoot [him] and put it over with.” His spouse instead left the house and spent the night in a hotel. The next morning, she was not able to achieve her husband by telephone, so she called the authorities to ask a welfare check.
The responding officers followed Caniglia’s spouse to the house, where they discovered Caniglia on the porch. The officers called an ambulance dependent on the belief which Caniglia posed a threat to others or himself. Caniglia agreed to go to the hospital for a psychiatric examination on the condition that the officers never confiscate his firearms. But, once Caniglia abandoned, the officers located and captured his weapons.
Caniglia filed suit, alleging that the officers had entered his house and seized him and his firearms without a warrant in violation of the Fourth Amendment. The First Circuit Court of Appeals affirmed, extrapolating in the Supreme Court’s conclusion in Cady v. Dombrowski, 413 U.S. 433 (1973), also a concept that the officers’ removal of Caniglia and his firearms from his residence was justified by a”community caretaking exception” to the warrant requirement. In support of its conclusion, the Court noted that police officers that patrol the”public highways” are usually called to release noncriminal”community care-taking functions,” such as responding to disabled vehicles or investigating accidents.
Supreme Court’s Conclusion
“The issue today is whether Cady’s correlation of those’caretaking’ duties produces a standalone doctrine that justifies warrantless searches and seizures in the house. It does not,” Justice Clarence Thomas wrote on behalf of the Court.
According to the Court, the First Circuit’s interpretation of the community caretaking principle”goes beyond anything that this court has recognized.” As Justice Thomas explainedthe”realization that police officers play many civic tasks in modern society was only that–
A realization that these tasks exist, rather than an open-ended license to perform them everywhere.”
In his view, Justice Thomas also emphasized that searches of vehicles and homes are constitutionally distinct. He additionally mentioned that Cady made this type of differentiation. “What’s reasonable for vehicles differs from what’s reasonable for homes,” Thomas wrote. “Cady acknowledged as much, and this Court has ‘diminished to expand the scope of both… exceptions to the warrant requirement to permit warrantless entry into your house. ”’