Caniglia v. Strom

• Decision Date: 17 May 2021
• Docket Number: No. 20-157,20-157
• Citation: 141 S.Ct. 1596,209 L.Ed.2d 604
• Parties: Edward A. CANIGLIA, Petitioner v. Robert F. STROM, et al.
• Court: U.S. Supreme Court

141 S.Ct. 1596

209 L.Ed.2d 604

Edward A. CANIGLIA, Petitioner

v.Robert F. STROM, et al.

No. 20-157

Supreme Court of the United States.

Argued March 24, 2021

Decided May 17, 2021

Thomas W. Lyons, Rhiannon S. Huffman, Strauss, Factor, Laing & Lyons, Providence, RI, Emma S. Gardner, Skadden, Arps, Slate, Meagher & Flom LLP, New York, NY, Shay Dvoretzky, Jonathan L. Marcus, Emily J. Kennedy, Sylvia O. Tsakos, Skadden, Arps, Slate, Meagher & Flom LLP, Washington, DC, for Petitioner.

Marc Desisto, Counsel of Record, Michael A. Desisto, Rebecca Tedford Partington, Kathleen M. Daniels, Desisto Law LLC, Providence, RI, Jonathan A. Herstoff, Haug Partners LLP, New York, NY, for Respondents.

Justice THOMAS delivered the opinion of the Court.

Decades ago, this Court held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment. Cady v. Dombrowski , 413 U.S. 433, 93 S.Ct. 2523, 37 L.Ed.2d 706 (1973). In reaching this conclusion, the Court observed that police officers who patrol the "public highways" are often called to discharge noncriminal "community caretaking functions," such as responding to disabled vehicles or investigating accidents. Id. , at 441, 93 S.Ct. 2523. The question today is whether Cady 's acknowledgment of these "caretaking" duties creates a standalone doctrine that justifies warrantless searches and seizures in the home. It does not.

I

During an argument with his wife at their Rhode Island home, Edward Caniglia (petitioner) 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 declined, and instead left to spend the night at a hotel. The next morning, when petitioner's wife discovered that she could not reach him by telephone, she called the police (respondents) to request a welfare check.

Respondents accompanied petitioner's wife to the home, where they encountered petitioner on the porch. Petitioner spoke with respondents and confirmed his wife's account of the argument, but denied that he was suicidal. Respondents, however, thought that petitioner posed a risk to himself or others. They called an ambulance, and petitioner agreed to go to the hospital for a psychiatric evaluation—but only after respondents allegedly promised not to confiscate his firearms. Once the ambulance had taken petitioner away, however, respondents seized the weapons. Guided by petitioner's wife—whom they allegedly misinformed about his wishes—respondents entered the home and took two handguns.

Petitioner sued, claiming that respondents 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 respondents, and the First Circuit affirmed solely on the ground that the decision to remove petitioner and his firearms from the premises fell within a "community caretaking exception" to the warrant requirement. Caniglia v. Strom , 953 F.3d 112, 121–123, 131 and nn. 5, 9 (2020). Citing this Court's statement in Cady that police officers often have noncriminal reasons to interact with motorists on "public highways," 413 U.S. at 441, 93 S.Ct. 2523, the First Circuit extrapolated a freestanding community-caretaking exception that applies to both cars and homes. 953 F.3d at 124 ("Threats to individual and community safety are not confined to the highways"). Accordingly, the First Circuit saw no need to consider whether anyone had consented to respondents' actions; whether these actions were justified by "exigent circumstances"; or whether any state law permitted this kind of mental-health intervention. Id., at 122–123. All that mattered was that respondents' efforts to protect petitioner 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." Id., at 123–128, 132–133. We granted certiorari. 592 U.S. ––––, 141 S.Ct. 870, 208 L.Ed.2d 436 (2020).

II

The Fourth Amendment protects "[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures." The " ‘very core’ " of this guarantee is " ‘the right of a man to retreat into his own home and there be free from unreasonable governmental intrusion.’ " Florida v. Jardines , 569 U.S. 1, 6, 133 S.Ct. 1409, 185 L.Ed.2d 495 (2013).

To be sure, the Fourth Amendment does not prohibit all unwelcome intrusions "on private property," ibid. —only "unreasonable" ones. We have thus recognized a few permissible invasions of the home and its curtilage. Perhaps most familiar, for example, are searches and seizures pursuant to a valid warrant. See Collins v. Virginia , 584 U.S. ––––, –––– – ––––, 138 S.Ct. 1663, 1670–71, 201 L.Ed.2d 9 (2018). We have also held that law enforcement officers may enter private property without a warrant when certain exigent circumstances exist, including the need to " ‘render emergency assistance to an injured occupant or to protect an occupant from imminent injury.’ " Kentucky v. King , 563 U.S. 452, 460, 470, 131 S.Ct. 1849, 179 L.Ed.2d 865 (2011) ; see also Brigham City v. Stuart , 547 U.S. 398, 403–404, 126 S.Ct. 1943, 164 L.Ed.2d 650 (2006) (listing other examples of exigent circumstances). And, of course, officers may generally take actions that " ‘any private citizen might do’ " without fear of liability. E.g., Jardines , 569 U.S. at 8, 133 S.Ct. 1409 (approaching a home and knocking on the front door).

The First Circuit's "community caretaking" rule, however, goes beyond anything this Court has recognized. The decision below assumed that respondents lacked a warrant or consent, and it expressly disclaimed the possibility that they were reacting to a crime. The court also declined to consider whether any recognized exigent circumstances were present because respondents had forfeited the point. Nor did it find that respondents' actions were akin to what a private citizen might have had authority to do if petitioner's wife had approached a neighbor for assistance instead of the police.

Neither the holding nor logic of Cady justified that approach. True, Cady also involved a warrantless search for a firearm. But the location of that search was an impounded vehicle—not a home—" ‘a constitutional difference’ " that the opinion repeatedly stressed. 413 U.S. at 439, 93 S.Ct. 2523 ; see also id., at 440–442, 93 S.Ct. 2523. In fact, Cady expressly contrasted its treatment of a vehicle already under police control with a search of a car "parked adjacent to the dwelling place of the owner." Id. , at 446–448, 93 S.Ct. 2523 (citing Coolidge v. New Hampshire , 403 U.S. 443, 91 S.Ct. 2022, 29 L.Ed.2d 564 (1971) ).

Cady 's unmistakable distinction between vehicles and homes also places into proper context its reference to "community caretaking." This quote comes from a portion of the opinion explaining that the "frequency with which ... vehicle[s] can become disabled or involved in ... accident[s] on public highways" often requires police to perform noncriminal "community caretaking functions," such as providing aid to motorists. 413 U.S. at 441, 93 S.Ct. 2523. But, this recognition that police officers perform many civic tasks in modern society was just that—a recognition that these tasks exist, and not an open-ended license to perform them anywhere.

* * *

What is reasonable for vehicles is different from what is reasonable for homes. Cady acknowledged as much, and this Court has repeatedly "declined to expand the scope of ... exceptions to the warrant requirement to permit warrantless entry into the home." Collins , 584 U.S., at ––––, 138 S.Ct. at 1672. We thus vacate the judgment below and remand for further proceedings consistent with this opinion.

It is so ordered.

Chief Justice ROBERTS, with whom Justice BREYER joins, concurring.

Fifteen years ago, this Court unanimously recognized that "[t]he role of a peace officer includes preventing violence and restoring order, not simply rendering first aid to casualties." Brigham City v. Stuart , 547 U.S. 398, 406, 126 S.Ct. 1943, 164 L.Ed.2d 650 (2006). A warrant to enter a home is not required, we explained, when there is a "need to assist persons who are seriously injured or threatened with such injury." Id., at 403, 126 S.Ct. 1943 ; see also Michigan v. Fisher , 558 U.S. 45, 49, 130 S.Ct. 546, 175 L.Ed.2d 410 (2009) (per curiam ) (warrantless entry justified where "there was an objectively reasonable basis for believing that medical assistance was needed, or persons were in danger" (internal quotation marks omitted)). Nothing in today's opinion is to the contrary, and I join it on that basis.

Justice ALITO, concurring.

I join the opinion of the Court but write separately to explain my understanding of the Court's holding and to highlight some important questions that the Court does not decide.

1. The Court holds—and I entirely agree—that there is no special Fourth Amendment rule for a broad category of cases involving "community caretaking." As I understand the term, it describes the many police tasks that go beyond criminal law enforcement. These tasks vary widely, and there is no clear limit on how far they might extend in the future. The category potentially includes any non-law-enforcement work that a community chooses to assign, and because of the breadth of activities that may be described as community caretaking, we should not assume that the Fourth Amendment's command of reasonableness applies in the same way to everything that might be viewed as falling into this broad category.

The Court's decision in Cady v. Dombrowski , 413 U.S. 433, 93 S.Ct. 2523, 37 L.Ed.2d 706 (1973), did not recognize any such "freestanding" Fourth Amendment category. See ante , at 1598 – 1599, 1599 – 1600. The opinion merely used the phrase "community caretaking" in passing. 413 U.S. at 441, 93 S.Ct. 2523.

2. While there is no overarching ...