The Supreme Court unanimously rejected Biden administration arguments in a case from Rhode Island that police should be allowed to enter homes without a warrant to seize handguns.
The ruling in the case, Caniglia v. Strom, court file 20-157, came May 17. Oral arguments took place telephonically on March 24.
The case came before the high court as President Joe Biden and congressional Democrats pressed for aggressive new restrictions on Second Amendment gun ownership rights, including controversial “red flag” laws, which allow gun seizures from law-abiding gun owners with limited due process, in the wake of highly publicized deadly mass shootings in March at a Boulder, Colorado, supermarket and at Atlanta-area spas.
Police generally cannot conduct searches of private property without consent or a warrant.
In Cady v. Dombrowski the Supreme Court held in 1973 that police may conduct warrantless searches related to “community caretaking functions,” but only for “vehicle accidents.” Since then, the principle has become “a catchall for a wide range of responsibilities that police officers must discharge aside from their criminal enforcement activities,” the 1st Circuit Court of Appeals stated in the Caniglia case.
The community caretaking doctrine holds that police don’t always operate as law enforcement officials investigating wrongdoing, but sometimes as caretakers to prevent harm in emergency situations.
Edward Caniglia has no criminal history and no record of violence. He had been married to his wife for 22 years when, on Aug. 20, 2015, they had a disagreement inside their Cranston, Rhode Island, home.
The argument escalated. He produced an unloaded gun and said, “Why don’t you just shoot me and get me out of my misery?”
Worried he might be suicidal, his wife asked police to conduct a welfare check. The husband went to a local hospital briefly after police assured him they wouldn’t take his two handguns. After he left, they seized his guns without a warrant, telling the wife his life and others could be in danger if they left the guns in the home. The police refused to return the weapons and Caniglia sued, arguing the community caretaking exception should not apply inside “the home–the most protected of all private spaces.”
Writing the Supreme Court’s short, 4-page opinion in the case, Justice Clarence Thomas noted the Cady v. Dombrowski precedent, which he indicated applied to police “responding to disabled vehicles or investigating accidents.”
“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,” Thomas wrote.
“It does not,” he added.
Thomas wrote that the federal district court ruled in favor of the police and the 1st Circuit expanded on this, stating that police “often have noncriminal reasons to interact with motorists” on public highways. The appeals court “extrapolated” from the Cady ruling “a freestanding community-caretaking exception that applies to both cars and homes.”
The appeals court’s community caretaking rule “goes beyond anything this Court has recognized,” Thomas wrote.
Chief Justice John Roberts filed a concurring opinion, in which Justice Stephen Breyer joined. Justices Samuel Alito and Brett Kavanaugh filed separate concurring opinions.
The ruling in the case, Caniglia v. Strom, court file 20-157, came May 17. Oral arguments took place telephonically on March 24.
The case came before the high court as President Joe Biden and congressional Democrats pressed for aggressive new restrictions on Second Amendment gun ownership rights, including controversial “red flag” laws, which allow gun seizures from law-abiding gun owners with limited due process, in the wake of highly publicized deadly mass shootings in March at a Boulder, Colorado, supermarket and at Atlanta-area spas.
Police generally cannot conduct searches of private property without consent or a warrant.
In Cady v. Dombrowski the Supreme Court held in 1973 that police may conduct warrantless searches related to “community caretaking functions,” but only for “vehicle accidents.” Since then, the principle has become “a catchall for a wide range of responsibilities that police officers must discharge aside from their criminal enforcement activities,” the 1st Circuit Court of Appeals stated in the Caniglia case.
The community caretaking doctrine holds that police don’t always operate as law enforcement officials investigating wrongdoing, but sometimes as caretakers to prevent harm in emergency situations.
Edward Caniglia has no criminal history and no record of violence. He had been married to his wife for 22 years when, on Aug. 20, 2015, they had a disagreement inside their Cranston, Rhode Island, home.
The argument escalated. He produced an unloaded gun and said, “Why don’t you just shoot me and get me out of my misery?”
Worried he might be suicidal, his wife asked police to conduct a welfare check. The husband went to a local hospital briefly after police assured him they wouldn’t take his two handguns. After he left, they seized his guns without a warrant, telling the wife his life and others could be in danger if they left the guns in the home. The police refused to return the weapons and Caniglia sued, arguing the community caretaking exception should not apply inside “the home–the most protected of all private spaces.”
Writing the Supreme Court’s short, 4-page opinion in the case, Justice Clarence Thomas noted the Cady v. Dombrowski precedent, which he indicated applied to police “responding to disabled vehicles or investigating accidents.”
“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,” Thomas wrote.
“It does not,” he added.
Thomas wrote that the federal district court ruled in favor of the police and the 1st Circuit expanded on this, stating that police “often have noncriminal reasons to interact with motorists” on public highways. The appeals court “extrapolated” from the Cady ruling “a freestanding community-caretaking exception that applies to both cars and homes.”
The appeals court’s community caretaking rule “goes beyond anything this Court has recognized,” Thomas wrote.
Chief Justice John Roberts filed a concurring opinion, in which Justice Stephen Breyer joined. Justices Samuel Alito and Brett Kavanaugh filed separate concurring opinions.
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