Caniglia v. Strom

141 S. Ct. 1596 (2021)

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Nature of the Case

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Facts

In an argument with his wife, P 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 spent the night at a hotel. The next morning, P’s wife discovered that she could not reach him by telephone, she called the police (Ds) to request a welfare check. Ds accompanied P’s wife to the home, where they saw P on the porch. P confirmed his wife’s account of the argument but denied that he was suicidal. Ds didn't believe P. They called an ambulance, and P agreed to go to the hospital for a psychiatric evaluation, but only after Ds allegedly promised not to confiscate his firearms. Once P was gone, Ds seized the weapons. Ds took two handguns. P sued claiming that Ds violated the Fourth Amendment when they entered his home and seized him and his firearms without a warrant. The District Court granted summary judgment to Ds, and the First Circuit affirmed solely on the ground that the decision to remove P and his firearms from the premises fell within a “community caretaking exception” to the warrant requirement. The First Circuit extrapolated a freestanding community-caretaking exception that applies to both cars and homes. All that mattered was that Ds’ efforts to protect P and those around him were “distinct from ‘the normal work of criminal investigation,’” fell “within the realm of reason,” and generally tracked what the court viewed to be “sound police procedure.” The Supreme Court granted certiorari.