Caniglia v. Strom (U.S. Supreme Court, May 2021)

The Federal Docket

May 21, 2021

4th Amendment – There is no distinct “community caretaking” exception to the 4th Amendment warrant requirement.

Edward Caniglia’s wife called the police to their shared home for a welfare check on her husband, who she believed may have been suicidal. Upon arrival, officers decided that Caniglia needed to be taken for a psychological evaluation, and he agreed to go—but only after the police assured him that they would not confiscate his firearms. Police then entered his house and confiscated his firearms.

Caniglia sued the police, claiming that the warrantless seizure of his person and his weapons were both in violation of his rights under the 4th Amendment. The District Court granted summary judgment to the officers, and the First Circuit affirmed, holding that that seizures were legal under the “community caretaking” exception to the warrant requirement as established by Cady v. Dombrowski.

A unanimous Supreme Court vacated that judgement and remanded. Cady did not create a special exception from the warrant requirement for actions taken while the police are engaged in “community caretaking.” The facts of that case—which involved the warrantless search of an impounded vehicle—are also not analogous to this one, which involved a personal home.

Chief Justice Roberts concurred separately to clarify that nothing in the opinion was inconsistent with the exigency exception to the warrant requirement in cases where people or injured or threatened with injury and need assistance.

Justice Alito wrote a concurring opinion as well, noting that while the Court disclaimed a special “community caretaking” exception to the warrant requirement, It was expressly not ruling on whether 4th Amendment jurisprudence in the criminal context would be applicable to all searches and seizures that were conducted for non-law-enforcement purposes. He went on to list several scenarios that are ungoverned by current precedent and may one day need to come before the Court for resolution.

Justice Kavanaugh also concurred separately. In his opinion he reiterated the points made by Chief Justice Roberts and then sought to clarify the doctrine of exigent circumstances by applying it to several hypothetical scenarios. These scenarios included one—that of an elderly person living alone, who has not been seen recently and is presumed to perhaps be in danger—that Justice Alito had conversely listed as being legally unresolved.

On certiorari from the First Circuit
Opinion by Thomas for a unanimous Court
Concurrence by Roberts, joined by Breyer
Concurrence by Alito
Concurrence by Kavanaugh

Click here to read the opinion

Tom Church - Tom is a trial and appellate lawyer focusing on criminal defense and civil trials. Tom is the author of "The Federal Docket" and is a contributor to Mercer Law Review's Annual Survey in the areas of federal sentencing guidelines and criminal law. Tom graduated with honors from the University of Georgia Law School where he served as a research assistant to the faculty in the areas of constitutional law and civil rights litigation. Read Tom's reviews on AVVO. Follow Tom on Linkedin.

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