By DANIEL KITTREDGE Cranston Police overstepped their authority in 2015 when they seized two firearms from the home of a man who was viewed as a potential risk to his own safety, the U.S. Supreme Court found in a unanimous opinion published Monday. "The
Cranston Police overstepped their authority in 2015 when they seized two firearms from the home of a man who was viewed as a potential risk to his own safety, the U.S. Supreme Court found in a unanimous opinion published Monday.
“The very core of the Fourth Amendment’s guarantee is the right of a person to retreat into his or her home and ‘there be free from unreasonable governmental intrusion,’” reads the court’s decision, which vacates a 2019 U.S. District Court finding in the case of Caniglia v. Strom et al. and sends the matter back to the lower court for new consideration. “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.”
Justice Clarence Thomas, who authored the high court’s opinion, added: “What is reasonable for vehicles is different from what is reasonable for homes.”
The American Civil Liberties Union of Rhode Island, which had filed a brief in support of the petitioner in the case, called the court’s decision an “important victory for privacy rights.”
“Today’s court decision is an extremely important victory for privacy rights,” ACLU of Rhode Island Executive Director Steven Brown said in a statement. “The Fourth Amendment has always served as an important barrier to police intrusion into the home, and we are very pleased that the Court reaffirmed this fundamental principle.”
The Caniglia v. Strom case stems back to 2015, when the local ACLU chapter filed a federal lawsuit on behalf of Edward Caniglia challenging both the seizure of his firearms by police and the Cranston Police Department’s policy against returning any confiscated firearm without a court order.
At the heart of the case was a “wellness check” police conducted at the request of Caniglia’s wife, who feared her husband had harmed himself when she was unable to contact him the day after an argument. During the course of that argument, Caniglia had retrieved an unloaded gun and suggested that his wife shoot him.
At the request of police, Canigilia underwent an evaluation at Kent Hospital and was soon discharged. But police still took two firearms from his home after his wife showed officers where the weapons were kept.
When the Caniglias attempted to retrieve the weapons from police, they were told a court order would be required. After the ACLU filed its legal action, the firearms were returned.
U.S. District Court Chief Judge John McConnell ruled in favor of Cranston Police in 2019, determining that the department had “operated within its duties to care for the community during the well-being check.” The ruling was later upheld by the First Circuit Court of Appeals.
Then, in August 2020, Caniglia asked the U.S. Supreme Court to take up the case. The court agreed to hear the matter in November, and oral arguments occurred in March. A number of organizations filed briefs in support of either Caniglia or the city of Cranston, represented in the title of the case by its finance director, Robert Strom.
The question at the center of the case was whether police are authorized to enter a home without a warrant in the interest of “community caretaking.” Thomas, in the court’s decision, cited the Supreme Court’s 1973 ruling in Cady v. Dombrowski, which found that “a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment” because “police officers who patrol the ‘public highways’ are often called to discharge noncriminal ‘community caretaking functions,’ such as responding to disabled vehicles or investigating accidents.”
“The question today is whether Cady’s acknowledgment of these ‘caretaking’ duties creates a standalone doctrine that justifies warrantless searches and seizures in the home,” Thomas wrote. “It does not.”
The opinion continues: “To be sure, the Fourth Amendment does not prohibit all unwelcome intrusions ‘on private property’ – only “unreasonable” ones. We have thus recognized a few permissible invasions of the home and its curtilage. Perhaps most familiar, for example, are searches and seizures pursuant to a valid warrant. We have also held that law enforcement officers may enter private property without a warrant when certain exigent circumstances exist, including the need to ‘render emergency assistance to an injured occupant or to protect an occupant from imminent injury.’ And, of course, officers may generally take actions that ‘any private citizen might do’ without fear of liability.”
It added: “The First Circuit’s ‘community caretaking’ rule, however, goes beyond anything this Court has recognized. The decision below assumed that respondents lacked a warrant or consent, and it expressly disclaimed the possibility that they were reacting to a crime. The court also declined to consider whether any recognized exigent circumstances were present because respondents had forfeited the point.”
Several justices authored concurring opinions focused on different aspect of the case.
Chief Justice John Roberts and Justice Stephen Breyer, in a joint concurring opinion, sought to clarify that the court’s finding would not impede the ability of police to enter a home “to assist persons who are seriously injured or threatened with such injury” and when “there was an objectively reasonable basis for believing that medical assistance was needed, or persons were in danger.”
Justice Samuel Alito, in his concurring opinion, noted that the decision does not address some situations law enforcement personnel may encounter. Neither, he wrote, does it address so-called “red flag” laws – like the one recently adopted in Rhode Island – nor the various laws states have on their books “allowing emergency seizures for psychiatric treatment, observation, or stabilization,” which “vary in many respects.”
“Perhaps States should institute procedures for the issuance of such warrants, but in the meantime, courts may be required to grapple with the basic Fourth Amendment question of reasonableness,” he wrote. “Searches and seizures conducted for other non-law-enforcement purposes may arise and may present their own Fourth Amendment issues. Today’s decision does not settle those questions.”
Justice Brett Kavanaugh also authored a brief concurring opinion “to underscore and elaborate on the chief justice’s point that the Court’s decision does not prevent police officers from taking reasonable steps to assist those who are inside a home and in need of aid.”
The court’s full opinion, as well as an audio recording and transcript of the March 24 oral arguments, can be found at www.supremecourt.gov.