Here’s some welcome news in the form of a rare 9-0 Supreme Court decision upholding Fourth Amendment rights against warrantless gun seizure:
In a unanimous opinion Monday, the U.S. Supreme Court ruled against police who seized a man’s guns without a warrant while he was in the hospital for a suicide evaluation.
Police cannot justify the warrantless search and seizure based on the “community caretaking” exception to the Fourth Amendment, Justice Clarence Thomas wrote in his opinion for the high court.
The Supreme Court had recognized the exception in a 1973 case, Cady v. Dombrowski, in which police searched the trunk of a car that had been towed after a crash.
The Supreme Court ruled Monday in a challenge by Edward Caniglia, who retrieved an unloaded gun during an argument with his wife, put it on the table and said, “Why don’t you just shoot me and get me out of my misery.”
Caniglia’s wife ended up spending the night at a motel. When she called her husband the next day, the wife was unable to reach him. She called police in Cranston, Rhode Island, for a wellness check.
Caniglia agreed to go to the hospital but only after police allegedly promised that they wouldn’t confiscate his firearms. Police entered Caniglia’s home and took two guns.
The 1st U.S. Circuit Court of Appeals at Boston had ruled against Caniglia, ruling that the community caretaking exception applies to homes and cars. The Supreme Court disagreed.
The 1st Circuit’s community caretaking rule “goes beyond anything this court has recognized,” Thomas wrote. “What is reasonable for vehicles is different from what is reasonable for homes. Cady acknowledged as much.”
The full text of the decision can be found here.
The First Circuit’s “community caretaking” rule, how-ever, goes beyond anything this Court has recognized. The decision below assumed that respondents lacked a warrantor 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.
Nor did it find that respondents’ actions were akin to what a private citizen might have had authority to do if petitioner’s wife had approached a neighbor for assistance in-stead of the police. Neither the holding nor logic of Cady justified that approach. True, Cady also involved a warrantless search for a firearm. But the location of that search was an impounded vehicle—not a home—“‘a constitutional difference’” that the opinion repeatedly stressed. 413 U. S., at 439; see also id., at 440–442. In fact, Cady expressly contrasted its treatment of a vehicle already under police control with a search of a car “parked adjacent to the dwelling place of the owner.” Id., at 446–448 (citing Coolidge v. New Hampshire, 403 U. S. 443 (1971)). Cady’s unmistakable distinction between vehicles and homes also places into proper context its reference to “community caretaking.” This quote comes from a portion of the opinion explaining that the “frequency with which . . . vehicle[s] can become disabled or involved in . . . accident[s] on public highways” often requires police to perform noncriminal “community caretaking functions,” such as providing aid to motorists. 413 U. S., at 441. But, this recognition that police officers perform many civic tasks in modern society was just that—a recognition that these tasks exist,and not an open-ended license to perform them anywhere.
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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.” Collins, 584 U. S., at ___ (slip op., at 8). We thus vacate the judgment below and remand for further proceedings consistent with this opinion.
In some ways this was a very narrowly tailored opinion, in that the Second Amendment was not invoked at all, only the Fourth. And indeed, Justice Samuel Alito’s concurring opinion specifically states that “Our decision today does not address those issues” in relation to the constitutionality of red flag laws. However, the decision was a blow for individual rights against warrentless police seizures in the home. Also, by explicitly including guns as property that is equally protected from such warrentless seizures, the Supreme Court has properly supported Second Amendment rights against the state’s overreach.
Now if they could do something about civil asset forfeitures…
Tags: Cady v. Dombrowski, Caniglia v. Strom, Clarence Thomas, Fourth Amendment, Guns, Samuel Alito, Supreme Court