The district court in Rhode Island granted summary judgment to the police on the sole ground that police were able to enter Mr. Caniglia’s home and take his handguns without a warrant as the police’s actions fell within the “community caretaking exception” outlined in the Cady decision, which allowed for a warrantless search of a person’s vehicle. On appeal, the First Circuit extrapolated a freestanding community-caretaking exception that applies to both cars and homes, holding that “threats to individual and community safety are not confined to the highways.” Because the First Circuit found that the community-caretaking exception applied, they did not consider other exceptions to the warrant requirement under the Fourth Amendment, such as consent to search, exigent circumstances, or whether any state law permitted this kind of mental-health intervention. Therefore, the Supreme Court’s review was solely whether the community-caretaking exception from Cady applied to a warrantless entry into a person’s home.
Justice Thomas delivered a succinct and direct opinion emphatically overturning the First Circuit and holding that the “community caretaking exception” does not extend to a warrantless search of a person’s home. Justice Thomas stated, “The First Circuit’s ‘community caretaking’ rule, however, goes beyond anything this Court has recognized.” Justice Thomas went on to state that “What is reasonable for vehicles is different from what is reasonable for homes. Cady acknowledged as much, and this Court has repeatedly “declined to expand the scope of . . . exceptions to the warrant requirement to permit warrantless entry into the home. We thus vacate the judgment below and remand for further proceedings consistent with this opinion.”
Practitioners who have a case involving a warrantless entry into a residence should read this opinion in its entirety as well as the three concurring opinions written by Justice Roberts, Justice Alito, and Justice Kavanaugh. Practitioners should ensure that any warrantless entry is not based upon a community-caretaking exception. If a practitioner has a case where a warrantless entry into a home occurred as a result of the community-caretaking exception, a motion to suppress should be filed to exclude any evidence received as a result of such entry.