After petitioner William Case called his former girlfriend and threatened suicide, she heard what sounded like a gun being cocked, followed by a “pop” and silence. Police responding to the home received no answer and observed, through the windows, empty beer cans, an empty handgun holster, and what appeared to be a suicide note. Officers entered the home without a warrant to provide emergency aid. Case, who had been hiding in a closet, emerged holding an object that appeared to be a gun and was shot by an officer. Police later recovered a handgun nearby.
Case was charged with assaulting a police officer and moved to suppress the evidence obtained after the warrantless entry. The Montana Supreme Court upheld the entry under its community-caretaker doctrine and rejected Case’s argument that officers needed probable cause to believe someone inside required emergency assistance.
The Supreme Court unanimously affirmed the judgment, though not all of the Montana Supreme Court’s reasoning. Writing for the majority, Justice Kagan explained that Brigham City v. Stuart already supplies the governing Fourth Amendment rule: officers may enter a home without a warrant when they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with serious injury. The Court declined to add a probable-cause requirement because probable cause is principally associated with criminal investigations, while an emergency-aid entry serves a different, non-investigative purpose.
The Supreme Court held that the officers satisfied the “emergency aid” standard based on the reported suicide threat, apparent gunshot, Case’s failure to respond, the empty holster, and the apparent suicide note. But the emergency-aid exception remains limited in scope: entry does not authorize officers to search beyond what is reasonably necessary to address the emergency and maintain their safety.
Justice Sotomayor concurred to emphasize that warrantless entry may not always be reasonable during a mental-health crisis. Different circumstances may require officers to consider de-escalation or other alternatives where entry itself could increase the danger.
Justice Gorsuch separately concurred, emphasizing the common-law tradition permitting entry onto another’s property when reasonably necessary to prevent serious physical harm.
Certiorari to the Supreme Court of Montana
Opinion by Kagan, joined by a unanimous Court
Concurring opinion by Sotomayor
Concurring opinion by Gorsuch
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