Caniglia v. Strom | |
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Argued March 24, 2021 Decided May 17, 2021 | |
Full case name | Edward A. Caniglia v. Robert F. Strom, et al. |
Docket no. | 20-157 |
Citations | 593 U.S. ___ ( more ) 141 S. Ct. 1596 209 L. Ed. 2d 604 |
Case history | |
Prior | |
Holding | |
Neither the holding nor logic of Cady justifies such warrantless searches and seizures in the home. | |
Court membership | |
| |
Case opinions | |
Majority | Thomas, joined by unanimous |
Concurrence | Roberts, joined by Breyer |
Concurrence | Alito |
Concurrence | Kavanaugh |
Laws applied | |
U.S. Const. amend. IV |
Caniglia v. Strom, 593 U.S. ___ (2021), was a United States Supreme Court case related to the Fourth Amendment to the United States Constitution's "community caretaking" exception.
During a heated argument in their home on August 20, 2015, Edward Caniglia grabbed a pistol from a bedroom and threw it on the dining room table. He then asked his wife, Kim, to shoot him with the gun. [1] Although whether the gun was loaded or not was in dispute, Kim hid the gun and the magazine while Edward left for a "ride" after the fight due to concern for his mental condition. As conflict brewed up after Edward returned home, Kim stayed at a hotel. At the hotel, she phoned a furious Edward that night, who brought up topics from the fight. The next day, Kim was unable to reach Edward through any means of contact. She then decided to contact the Cranston, Rhode Island Police Department's non-emergency line because Kim feared he harmed himself after the tirades. Talking with Officer Mastrati, she mentioned the argument, Edward's behavior, and the firearm. Kim clarified that she was not in danger but worried that her husband was in danger. She was further afraid of what she might discover if she returned home. Mastrati called Edward, who agreed to meet with the police. Officers Mastrati, Smith, Russell, and Sergeant Barth met with him outside the Caniglia household. Kim was waiting nearby in her car. Barth observed Caniglia as appearing "agitated" and "angry" while Mastrati and Russell noted "calm," "cooperative," and "normal" behavior. Kim also remarked that Edward was upset that police were called. Sergeant Barth ultimately concluded that Edward posed a danger to himself and others. He then agreed with Barth's request to receive a psychiatric evaluation at a nearby hospital. According to Edward, he complied with the request only because the officers promised they would not confiscate his weapons if he sought treatment. On that same morning, one of the Caniglias informed police that another firearm was present in the home. Barth asked his superiors to confiscate the firearms, with Captain Henry approving the proposal. Kim directed the officers to the locations of the weapons, along with the magazines and associated ammunition. Police knew that Edward owned the items and did not want them seized. After multiple attempts to retrieve the firearms back from the police department, his lawyer requested in October 2015 that the guns be returned to Edward. Two months later, the firearms were returned. Shortly before getting the guns back, Edward sued the City of Cranston and the police department for violating his 4th Amendment rights.
In its decision, the United States District Court for the District of Rhode Island analyzed Edward Caniglia's case on ten factors (Fourth Amendment law, the community caretaking exception, qualified immunity, the Second Amendment of the United States Constitution, Article I, § 22 of the Constitution of Rhode Island, Fourteenth Amendment Due Process, Fourteenth Amendment Equal Protection, the Rhode Island Firearms Act, the Rhode Island Mental Health Law, and Caniglia's claim of conversion). [2] Issuing a summary judgement, the district court ruled that Caniglia 's due process rights were infringed because the police failed to return his property or instruct him on retrieving his firearms after he was deemed safe. However, the court denied his other claims of conversion, violation of the RIMHL, and violation of 4th Amendment rights. Additionally, the district court judges decided that the officers acted reasonably based on the reports from Kim Caniglia. Rebutting Edward Caniglia's claim that the community caretaking exception only applies to vehicles, qualified immunity was granted to the officers because case law and judicial attitudes towards community caretaking involving the home were ambiguous at best and poorly defined at worst. Furthermore, Caniglia's right to bear arms was not violated because police reasonably asserted he was suicidal and his guns were eventually returned; his Equal Protection claim also faltered because merely speculated about the fate of gun owners in Cranston rather than pointing out the treatment of a specific individual. Claims for compensation were denied under the RIFA because the police returned the guns to Caniglia without a court order. Caniglia was neither stopped nor arrested for law enforcement purposes; he was only detained as part of community caretaking duties. Finally, the police department did not violate the RIMHL because there was no evidence of a conspiracy to admit Caniglia, and that he was briefly evaluated and released without law enforcement encouraging staff to have him stay.
The United States Court of Appeals for the First Circuit affirmed the district court's decision by declaring, "Police officers play an important role as community caretakers.... Here, the actions of the defendant officers, though not letter perfect, did not exceed the proper province of their community caretaking responsibilities." [3]
Certiorari was granted in the case on November 20, 2020. The case was argued on March 24, 2021, and decided on May 17, 2021. In a unanimous decision (9-0), Justice Clarence Thomas delivered the majority opinion. [4] In Caniglia's case, the community caretaking exception was used far beyond the bounds of the 4th Amendment: [5]
Chief Justice John Roberts (joined by Justice Stephen Breyer) declares that the court unanimously recognized in Brigham City v. Stuart that the role of the police is to prevent violence and restore order rather than merely rendering aid to casualties. [6] A warrant is not required when there is a need to assist those who are seriously injured or threatened with such injury. Although warrantless entry is justified if there is an objectively reasonable basis that a party was in need of medical assistance or in serious danger, the facts described in the opinion do not contradict case law. Therefore, Roberts fully agrees with the majority.
While Justice Samuel Alito agreed that there is no broad 4th Amendment rule for community caretaking, he opines that specific scenarios such as conducting a search and seizure on a suicidal person, red flag laws, and warrantless searches to check on a resident's medical condition were not properly addressed. [7] He further writes:
Justice Brett Kavanaugh concurred that although he agrees with the Court fully, he argues that the decision clarifies labeling more than ramifications. While the community caretaking doctrine applies to primarily vehicles, the exigent circumstances doctrine could very well apply to Caniglia. [8]
The Fourth Amendment to the United States Constitution is part of the Bill of Rights. It prohibits unreasonable searches and seizures. In addition, it sets requirements for issuing warrants: warrants must be issued by a judge or magistrate, justified by probable cause, supported by oath or affirmation, and must particularly describe the place to be searched and the persons or things to be seized.
Search and seizure is a procedure used in many civil law and common law legal systems by which police or other authorities and their agents, who, suspecting that a crime has been committed, commence a search of a person's property and confiscate any relevant evidence found in connection to the crime.
In criminal procedure law of the United States, an exigent circumstance allows law enforcement to enter a structure without a search warrant, or if they have a "knock and announce" warrant, allows them to enter without knocking and waiting for the owner's permission to enter. It must be a situation where people are in imminent danger, evidence faces imminent destruction, or a suspect's escape is imminent. Once entry is obtained, the plain view doctrine applies, allowing the seizure of any evidence or contraband discovered in the course of actions consequent upon the exigent circumstances.
In common law, the curtilage of a house or dwelling is the land immediately surrounding it, including any closely associated buildings and structures, but excluding any associated "open fields beyond". In feudal times every castle with its dependent buildings was protected by a surrounding wall, and all the land within the wall was termed the curtilage. The term excludes any closely associated buildings, structures, or divisions that contain the separate intimate activities of their own respective occupants, with those occupying residents being persons other than those residents of the house or dwelling of which the building is associated.
Brigham City v. Stuart, 547 U.S. 398 (2006), is a United States Supreme Court case involving the exigent circumstances exception to the Fourth Amendment's warrant requirement. The Court ruled that police may enter a home without a warrant if they have an objectively reasonable basis for believing that an occupant is or is about to be seriously injured.
South Dakota v. Opperman, 428 U.S. 364 (1976), elaborated on the community caretaking doctrine. Under the Fourth Amendment, "unreasonable" searches and seizures are forbidden. In addition to their law-enforcement duties, the police must engage in what the court has termed a community caretaking role, including such duties as removing obstructions from roadways to ensure the free flow of traffic. When the police act in this role, they may inventory cars they have seized without "unreasonably" searching those cars.
Payton v. New York, 445 U.S. 573 (1980), was a United States Supreme Court case concerning warrantless entry into a private home in order to make a felony arrest. The Court struck down a New York statute providing for such warrantless entries because the Fourth Amendment draws a firm line at the entrance to the house. Absent exigent circumstances, that threshold may not be reasonably crossed without a warrant. The court, however, did specify that an arrest warrant would have sufficed for entry into the suspect's residence if there had been reason to believe that the suspect was within the home.
Welsh v. Wisconsin, 466 U.S. 740 (1984), was a 1983 case before the US Supreme Court determining that a warrantless home arrest without exigent circumstances violates the Fourth Amendment protection against unlawful search and seizure.
Carroll v. United States, 267 U.S. 132 (1925), was a decision by the United States Supreme Court that upheld the warrantless searches of an automobile, which is known as the automobile exception. The case has also been cited as widening the scope of search.
Schmerber v. California, 384 U.S. 757 (1966), was a landmark United States Supreme Court case in which the Court clarified the application of the Fourth Amendment's protection against warrantless searches and the Fifth Amendment right against self-incrimination for searches that intrude into the human body. Until Schmerber, the Supreme Court had not yet clarified whether state police officers must procure a search warrant before taking blood samples from criminal suspects. Likewise, the Court had not yet clarified whether blood evidence taken against the wishes of a criminal suspect may be used against that suspect in the course of a criminal prosecution.
Almeida-Sanchez v. United States, 413 U.S. 266 (1973), was a United States Supreme Court case holding that the search of an automobile by the United States Border Patrol without a warrant or probable cause violates the Fourth Amendment. The vehicle was stopped and searched for illegal aliens twenty-five miles (40 km) from the Mexican border. The Court approached the search from four views: automobile search, administrative inspection, heavily regulated industry inspection, and border search. As to the validity of the search under the automobile exception, the Court found no justification for the search under the Carroll doctrine because there was no probable cause. As to the validity of the search under various administrative inspection doctrines, the Court found that the officers lacked an area warrant. As to the validity of the heavily regulated industry inspection, the Court found that the doctrine is not applicable to traveling on a state highway. As to the validity of a border search, the Court found that the site of the stop and the entirety of the road on which the stop occurred was too far from the border to be considered a border search.
Kentucky v. King, 563 U.S. 452 (2011), was a decision by the US Supreme Court, which held that warrantless searches conducted in police-created exigent circumstances do not violate the Fourth Amendment as long as the police did not create the exigency by violating or threatening to violate the Fourth Amendment.
Missouri v. McNeely, 569 U.S. 141 (2013), was a case decided by United States Supreme Court, on appeal from the Supreme Court of Missouri, regarding exceptions to the Fourth Amendment to the United States Constitution under exigent circumstances. The United States Supreme Court ruled that police must generally obtain a warrant before subjecting a drunken-driving suspect to a blood test, and that the natural metabolism of blood alcohol does not establish a per se exigency that would justify a blood draw without consent.
The Supreme Court of the United States handed down eight per curiam opinions during its 2013 term, which began October 7, 2013 and concluded October 5, 2014.
R v Fearon, 2014 SCC 77 is a leading section 8 Canadian constitutional law case, concerning the constitutionality of warrantless law enforcement searches of the contents of a cell phone incident to arrest.
United States v. Watson, 423 U.S. 411 (1976), was a case decided by the Supreme Court of the United States that decided that a warrantless arrest in public and consenting to a vehicle search did not violate the Fourth Amendment.
Birchfield v. North Dakota, 579 U.S. 438 (2016) is a case in which the Supreme Court of the United States held that the search incident to arrest doctrine permits law enforcement to conduct warrantless breath tests but not blood tests on suspected drunk drivers.
Mitchell v. Wisconsin, 588 U.S. ___ (2019), is a United States Supreme Court case in which the Court held that "when a driver is unconscious and cannot be given a breath test, the exigent-circumstances doctrine generally permits a blood test without a warrant."
Johnson v. United States, 333 U.S. 10 (1948), was a significant United States Supreme Court decision addressing search warrants and the Fourth Amendment. In this case, where federal agents had probable cause to search a hotel room but did not obtain a warrant, the Court declared the search was "unreasonable."
Lange v. California, 594 U.S. ___ (2021), was a United States Supreme Court case involving the exigent circumstances requirement related to the Fourth Amendment to the United States Constitution. The Court ruled unanimously that the warrantless entry into a home by police in pursuit of a misdemeanant is not unequivocally justified.