Community Caretaking Not Applicable to Warrantless Home Searches

In Canigla, the Supreme Court held that the community caretaking doctrine did not apply to warrantless home searches.

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On May 17, 2021, the Supreme Court issued an opinion in Canigla vs. Strom, No. 20–157.  In Canigla, the Supreme Court held that the “community caretaking” duties do not extend to the warrantless search and seizure of a home.

Canigla’s Weapons and the Police

Canigla had an argument with his wife.  During that argument he retrieved a handgun from the bedroom and asked his wife to “shoot [him] now and get it over with.”  His wife did not shoot him, opting instead to spend the night at a hotel.  The next morning, she tried to call him but he did not answer.  She asked the police for a welfare check. 

The police arrived at Canigla’s house, asking him questions.  He denied that he was suicidal.  He agreed to go to a hospital for a psychological evaluation, but only after the police promised not to confiscate his guns.  Once the ambulance took Canigla, the police went inside the house and took the guns. 

Canigla’s Sues Over Community Caretaking Exception

Canigla sued, indicating that the police violated the Fourth Amendment when they went into his home without a warrant.  The district court tossed the case out. The First Circuit affirmed because the need to take the guns fell within the “community caretaking exception.” This is based on the idea that police officers have noncriminal reasons to interact with motorists on “public highways,” to the warrant requirement. 

Community Caretaking as Applied Here

Normally, the police must consider whether they have consent, an exception to the warrant requirement.  This would be like “exigent circumstances” or a state-law exception to the warrant requirement. All that mattered in this instance, was whether the efforts to protect Canigla were “distinct from the normal work of criminal investigation, fell within the realm of reason,” and tracked what the court viewed to be “sound police procedure.” 

The Supreme Court’s Decision

The Supreme Court determined that the “community caretaking” rule that the First Circuit used was beyond what the court recognized.  The First Circuit’s decision assumed that the officers did not have a warrant or consent.  The First Circuit did not evaluate whether the officers were investigating a crime.

The Supreme Court noted that the First Circuit was using a Supreme Court case, United States vs. Cady, to make this decision but the difference was that the place at issue in Cady was a car, not a home.  Even in the Cady case the court stated that there was a difference between a car under police control and a car that was “parked adjacent to the dwelling place of the owner.” 

The Court reasoned that the community caretaking doctrine does mention that there are situations where cars get stuck on the road or accidents.  But this does not give the police to perform these tasks anywhere.  The police officers did not have a warrant and they entered his home.  That is just not allowed in this instance. 

The Supreme Court vacated the judgment and sent the case back down for further proceedings. 

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