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 a 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 requirement in the context of searches and seizures in homes.  Finding that the First Circuit’s recognition of a freestanding community caretaking exception to the warrant requirement went “beyond anything this Court has recognized,” the Court vacated the judgment below and remanded for further proceedings.

Chief Justice Roberts, joined by Justice Breyer, concurred by noting that the Court’s opinion was not contrary to the exigent circumstances doctrine.  Justice Alito concurred by noting his view that the Court correctly had rejected a special Fourth Amendment rule for a broad category of cases involving “community caretaking” but had not settled difficult questions about the parameters of all searches and seizures conducted for “non-law-enforcement purposes.”  Justice Kavanaugh concurred and elaborated on his observations of the applicability of the exigent circumstances doctrine in cases where officers enter homes without warrants to assist persons in need of aid.