Caniglia v. Strom

593 U.S. 194, 209 L. Ed. 2d 604, 141 S. Ct. 1596
CourtSupreme Court of the United States
DecidedMay 17, 2021
Docket20-157
StatusPublished
Cited by138 cases

This text of 593 U.S. 194 (Caniglia v. Strom) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caniglia v. Strom, 593 U.S. 194, 209 L. Ed. 2d 604, 141 S. Ct. 1596 (2021).

Opinion

(Slip Opinion) OCTOBER TERM, 2020 1

Syllabus

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

CANIGLIA v. STROM ET AL.

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT

No. 20–157. Argued March 24, 2021—Decided May 17, 2021 During an argument with his wife, petitioner Edward Caniglia placed a handgun on the dining room table and asked his wife to “shoot [him] and get it over with.” His wife instead left the home and spent the night at a hotel. The next morning, she was unable to reach her hus- band by phone, so she called the police to request a welfare check. The responding officers accompanied Caniglia’s wife to the home, where they encountered Caniglia on the porch. The officers called an ambu- lance based on the belief that Caniglia posed a risk to himself or others. Caniglia agreed to go to the hospital for a psychiatric evaluation on the condition that the officers not confiscate his firearms. But once Caniglia left, the officers located and seized his weapons. Caniglia sued, claiming that the officers had entered his home and seized him and his firearms without a warrant in violation of the Fourth Amend- ment. The District Court granted summary judgment to the officers. The First Circuit affirmed, extrapolating from the Court’s decision in Cady v. Dombrowski, 413 U. S. 433, a theory that the officers’ removal of Caniglia and his firearms from his home was justified by a “commu- nity caretaking exception” to the warrant requirement. Held: Neither the holding nor logic of Cady justifies such warrantless searches and seizures in the home. Cady held that a warrantless search of an impounded vehicle for an unsecured firearm did not vio- late the Fourth Amendment. In reaching this conclusion, the Court noted that the officers who patrol the “public highways” are often called to discharge noncriminal “community caretaking functions,” such as responding to disabled vehicles or investigating accidents. 413 U. S., at 441. But searches of vehicles and homes are constitutionally different, as the Cady opinion repeatedly stressed. Id., at 439, 440– 442. The very core of the Fourth Amendment’s guarantee is the right 2 CANIGLIA v. STROM

of a person to retreat into his or her home and “there be free from un- reasonable governmental intrusion.” Florida v. Jardines, 569 U. S. 1, 6. A recognition of the existence of “community caretaking” tasks, like rendering aid to motorists in disabled vehicles, is not an open-ended license to perform them anywhere. Pp. 3–4. 953 F. 3d 112, vacated and remanded.

THOMAS, J., delivered the opinion for a unanimous Court. ROBERTS, C. J., filed a concurring opinion, in which BREYER, J., joined. ALITO, J., and KAVANAUGH, J., filed concurring opinions. Cite as: 593 U. S. ____ (2021) 1

Opinion of the Court

NOTICE: This opinion is subject to formal revision before publication in the preliminary print of the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Wash- ington, D. C. 20543, of any typographical or other formal errors, in order that corrections may be made before the preliminary print goes to press.

SUPREME COURT OF THE UNITED STATES _________________

No. 20–157 _________________

EDWARD A. CANIGLIA, PETITIONER v. ROBERT F. STROM, ET AL. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT [May 17, 2021]

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 vio- late the Fourth Amendment. Cady v. Dombrowski, 413 U. S. 433 (1973). In reaching this conclusion, the Court ob- served that police officers who patrol the “public highways” are often called to discharge noncriminal “community care- taking functions,” such as responding to disabled vehicles or investigating accidents. Id., at 441. The question today is whether Cady’s acknowledgment of these “caretaking” duties creates a standalone doctrine that justifies warrant- less 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 (re- spondents) to request a welfare check. 2 CANIGLIA v. STROM

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. Respond- ents, however, thought that petitioner posed a risk to him- self 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 confis- cate 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. 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 mo- torists on “public highways,” 413 U. S., at 441, the First Cir- cuit extrapolated a freestanding community-caretaking ex- ception 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 per- mitted this kind of mental-health intervention. Id., at 122– 123. All that mattered was that respondents’ efforts to pro- tect 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 Cite as: 593 U. S. ____ (2021) 3

viewed to be “sound police procedure.” Id., at 123–128, 132– 133. We granted certiorari. 592 U. S. ___ (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 govern- mental intrusion.’ ” Florida v. Jardines, 569 U. S. 1, 6 (2013). To be sure, the Fourth Amendment does not prohibit all unwelcome intrusions “on private property,” ibid.—only “unreasonable” ones.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Michael Gene Wiskowski
2024 WI 23 (Wisconsin Supreme Court, 2024)
Pulsifer v. Prince
D. Maryland, 2024
Cardinale v. Jones
E.D. California, 2024
Thompson v. Cockrell
E.D. Missouri, 2024
State of New Jersey v. Alfonso Bowen, Jr.
New Jersey Superior Court App Division, 2024
Cook v. Boss
N.D. Ohio, 2024
Sanford v. Kirst
M.D. Louisiana, 2024
Thomas v. Town of Lloyd
N.D. New York, 2024
United States v. Antoine Maxwell
89 F.4th 671 (Eighth Circuit, 2023)
Dcpp v. D.B. and D.H., in the Matter of S.B.
New Jersey Superior Court App Division, 2023
People v. Hagestedt
2023 IL App (2d) 210715-U (Appellate Court of Illinois, 2023)
Garnett v. State
Supreme Court of Delaware, 2023
United States v. Jaron Howard Morgan
71 F.4th 540 (Sixth Circuit, 2023)
Watkins v. Smith (125)
W.D. Arkansas, 2023
People of Michigan v. Azucena Ajungo
Michigan Court of Appeals, 2023
State of Iowa v. Santos Rene Torres
Supreme Court of Iowa, 2023
State of Iowa v. Sam Daniel Abu Youm
Supreme Court of Iowa, 2023

Cite This Page — Counsel Stack

Bluebook (online)
593 U.S. 194, 209 L. Ed. 2d 604, 141 S. Ct. 1596, Counsel Stack Legal Research, https://law.counselstack.com/opinion/caniglia-v-strom-scotus-2021.