## Facts

- After a heated argument at home, Edward Caniglia placed a handgun on a table and told his wife to “shoot [him] and get it over with.”
- His wife left overnight and, unable to reach him the next morning, called police for a welfare check, reporting his statements and the presence of a firearm.
- Officers accompanied her to the home and found Caniglia on the porch; accounts differed as to whether he appeared agitated or calm.
- An officer concluded Caniglia posed a danger and called an ambulance; Caniglia agreed to go for a psychiatric evaluation, allegedly after officers promised not to confiscate his weapons if he went voluntarily.
- After Caniglia left by ambulance, officers entered the home and seized firearms and ammunition.
- Officers asserted the wife consented to the entry and seizure; Caniglia disputed consent.
- Caniglia was evaluated at a hospital but not admitted; after months, his firearms were returned, and he sued alleging a Fourth Amendment violation.

## Issues

1. Whether a “community caretaking” exception to the Fourth Amendment warrant requirement authorizes warrantless entry into a home and seizure of firearms.
2. Whether the “community caretaking” rationale recognized for vehicle-related policing justifies home searches and seizures independent of traditional exceptions such as consent or exigent circumstances.

## Decision

- The Supreme Court unanimously vacated the First Circuit’s judgment and remanded.
- The Court held that neither the holding nor logic of precedent recognizing “community caretaking” functions in the vehicle context justifies a warrantless home entry and seizure under a freestanding “community caretaking” exception.
- The Court did not decide whether the entry and seizure were lawful under other doctrines (e.g., exigent circumstances or consent), leaving those questions for further proceedings.

## Legal Principles

- The Fourth Amendment affords heightened protection to the home; warrantless home entry is presumptively unreasonable absent a recognized exception.
- References to “community caretaking” in vehicle-search precedent do not create an open-ended doctrine permitting warrantless searches and seizures in residences.
- Existing exceptions—such as exigent circumstances (including emergency aid) and voluntary consent—remain the proper frameworks for evaluating warrantless entries related to welfare checks or emergencies.
- Police authority to respond to genuine in-home emergencies is governed by objective reasonableness under established exigent-circumstances and emergency-aid rules, not by a standalone “community caretaking” category.

## Conclusion

The Court rejected a standalone “community caretaking” exception for warrantless home entry and firearm seizure, reaffirming the home’s special Fourth Amendment status and directing courts to analyze emergency responses under traditional exceptions such as exigent circumstances and consent.


Caniglia v. Strom, 593 U.S. 194 (2021)