Case Summaries: U.S. Supreme Court (May 17, 2021)

This post summarizes decisions released by the United States Supreme Court on May 17, 2021.  As always, they will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to present. Caniglia v. Strom, 593 U.S. ___, ___ S. Ct. ___ (May 17, 2021).  In this case involving a welfare check that resulted in officers entering petitioner Caniglia’s home without a warrant and seizing his firearms, the court held that its decision in Cady v. Dombrowski, 413 U.S. 433 (1973) upholding as reasonable a “caretaking search” of an impounded vehicle for a firearm did not create a standalone doctrine that justifies warrantless searches and seizures in the home.  Following an argument where Caniglia put a gun on a table and told his wife to shoot him, officers accompanied his wife to their shared home to assess his welfare.  During that visit, Caniglia agreed to be taken for a mental health evaluation and officers entered his home to confiscate two pistols against his expressly stated wishes.  Caniglia later sued, alleging that officers violated his Fourth Amendment rights by the warrantless seizure of him and his pistols. The First Circuit affirmed summary judgment for the officers solely on the basis that the seizures fell within a freestanding “community caretaking exception” to the warrant requirement it extrapolated from Cady.  Writing for the unanimous court, Justice Thomas noted Cady’s “unmistakable distinction between vehicles and homes” and the Court’s repeated refusal to expand the scope of exceptions to the warrant [...]