SCOTUS Opinion: “Community Caretaking Exception” To The Fourth Amendment Blocked From The Home

In Caniglia v. Strom, after Edward Caniglia agreed to submit to a psychiatric evaluation and was taken by ambulance to the hospital, officers searched his home and seized his firearms without a search warrant. Caniglia sued, but the district court and the First Circuit rejected his suit under the “community caretaking exception” to the warrant requirement of the Fourth Amendment, which was held in Cady v. Dombrowski, 413 U.S. 433 (1973) to permit officers to search an impounded car without a warrant as part of their typical protective obligations.

The Court, in a brief, unanimous decision by Justice Thomas, reversed, holding that the exception only properly applied to searches of already-impounded vehicles—nothing in that decision could be extrapolated to a search of the home. “What is reasonable for vehicles is different from what is reasonable for homes,” the majority reasoned, and the search and seizure of Caniglia’s firearms did not fit under any of the exceptions for reasonable warrantless home searches, and thus could not be permitted. Chief Justice Roberts, joined by Justice Breyer, wrote a one-paragraph concurrence noting that, in his view, nothing in this decision curtailed the police from entering a home “to assist persons who are seriously injured or threatened with such injury.” Justice Alito’s concurrence noted several other areas of law left untouched by this decision, to highlight its narrow holding. Justice Kavanaugh wrote his own concurrence to emphasize the Chief Justice’s argument.

A link to the decision is here: