SCOTUS: Justices Reject Broadening the So-Called “Community Caretaking Exception” to the Warrant Requirement

Protecting the sanctity of the home, the Supreme Court declines to expand police authority to conduct warrantless searches in the name of "community caretaking" functions.

The Supreme Court unanimously decided that police officers who were performing a welfare check did not have the authority to enter the man's home without a warrant and seize his guns.

The case in question involved Mr. Caniglia and his wife. The couple had an argument in which Mr. Caniglia told his wife: "Why don't you just shoot me and get me out of my misery?" The wife left and tried to get ahold of him the next day. When she couldn't, she called the police to ask for a welfare check. Mr. Caniglia told officers he wasn't suicidal but agreed to voluntarily undergo a psychiatric evaluation on the condition that the officers not take his guns. Once Mr. Caniglia left, the officers seized the guns out of safety concerns because they believed him to be suicidal. Mr. Caniglia sued, alleging the warrantless search and seizure were unconstitutional.

The Fourth Amendment protects people and their homes from unreasonable searches and seizures by the government. In most instances, a police officer will need to secure a warrant from a judge by showing probable cause exists to believe that evidence of a crime will be found at the location to be searched. The law, however, recognizes certain exceptions to the warrant requirements, such as when a person consents to the search, an emergency exists, or police impound a vehicle. These recognized exceptions will generally justify a warrantless search.

In the Caniglia case, the justices rejected a standalone exception to the warrant requirement for what's become known as a police officer's "community caretaking duties." Community caretaking functions refer to law enforcement's role in responding to noncriminal activities that are related to public safety, such as vehicle accidents and welfare checks.

The Court acknowledged that, during a welfare check, an officer could enter the home without a warrant to assist a person who's believed to be injured or in danger. But no such emergency existed in Mr. Caniglia's case—he told the officers he was not suicidal and agreed to go to the hospital. No criminal activity was afoot either. The Court decided that the police went too far by using their "community caretaking role" to conduct a warrantless search of the home and seize his weapons.

Held: Police "community caretaking" duties, standing alone, do not permit a warrantless search of a person's home.

Caniglia v. Strom, 593 U.S. ____ (2021).

Decided: May 17, 2021.