141 S. Ct. 1596 (2021)
During an argument with his wife, petitioner Edward Caniglia placed a handgun on the dining room table and asked his wife to "shoot [him] and get it over with." His wife left the home and spent the night at a hotel. The next morning, unable to reach her husband by phone, she called the police to request a welfare check. Responding officers accompanied Caniglia's wife to the home and encountered Caniglia on the porch. The officers called an ambulance based on the belief that Caniglia posed a risk to himself or others. Caniglia agreed to go to the hospital for a psychiatric evaluation on the condition that the officers not confiscate his firearms. After Caniglia left, the officers located and seized his weapons.
Caniglia sued, claiming that the officers entered his home and seized him and his firearms without a warrant in violation of the Fourth Amendment. The District Court granted summary judgment to the officers, and the First Circuit affirmed, extrapolating from this Court's decision in Cady v. Dombrowski a theory that the officers' removal of Caniglia and his firearms from his home was justified by a "community caretaking exception" to the warrant requirement.
Held: Neither the holding nor the logic of Cady justifies warrantless searches and seizures in the home. Cady held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment, and explained that officers who patrol the public highways often discharge noncriminal "community caretaking functions," such as responding to disabled vehicles or investigating accidents. But searches of vehicles and homes are constitutionally different. The very core of the Fourth Amendment's guarantee is the right to retreat into ones home and be free from unreasonable governmental intrusion. A recognition that "community caretaking" tasks exist is not an open-ended license to perform them anywhere.
Decades ago, this Court held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment. In reaching that conclusion, the Court observed that police officers who patrol public highways are often called to discharge noncriminal "community caretaking functions," such as responding to disabled vehicles or investigating accidents. The question here is whether Cady's acknowledgment of these caretaking duties creates a standalone doctrine that justifies warrantless searches and seizures in the home. It does not.
During an argument with his wife at their Rhode Island home, Edward Caniglia retrieved a handgun from the bedroom, put it on the dining room table, and asked his wife to "shoot [him] now and get it over with." She left and spent the night at a hotel. The next morning, when she could not reach him by telephone, she called the police to request a welfare check. Officers accompanied Caniglia's wife to the home, where they encountered Caniglia on the porch. Caniglia confirmed his wife's account of the argument but denied that he was suicidal. The officers concluded he posed a risk to himself or others, called an ambulance, and Caniglia agreed to go to the hospital for a psychiatric evaluationallegedly after the officers promised not to confiscate his firearms. Once Caniglia left, however, the officers entered the home, guided by the wife's direction, and seized two handguns.
Caniglia sued, alleging Fourth Amendment violations based on the officers' warrantless entry and seizure. The District Court granted summary judgment for the officers, and the First Circuit affirmed solely on the ground that the removal of Caniglia and his firearms fell within a "community caretaking exception" to the warrant requirement. Relying on Cady's statement that police frequently perform noncriminal caretaking on public highways, the First Circuit extrapolated a freestanding community-caretaking exception that applies to both cars and homes, and therefore did not consider consent, exigent-circumstances doctrines, or applicable state law governing mental-health interventions. We granted certiorari.
The Fourth Amendment protects the right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures. The very core of this guarantee is the right to retreat into one's home and be free from unreasonable governmental intrusion.
The Fourth Amendment does not prohibit all unwelcome intrusions on private propertyonly "unreasonable" ones. The Court has recognized a few permissible invasions of the home and its curtilage: searches and seizures pursuant to a valid warrant; entries without a warrant when exigent circumstances exist (including the need to render emergency assistance or protect an occupant from imminent injury); and actions by officers that any private citizen might take (for example, approaching a home and knocking on the door).
The First Circuit's community-caretaking rule goes beyond these recognized doctrines. The court below assumed the officers lacked a warrant or consent and disclaimed they were reacting to a crime. It declined to consider exigent-circumstances justifications and did not treat the officers' conduct as akin to what a private citizen might do. Neither the holding nor the logic of Cady justifies that approach.
True, Cady involved a warrantless search for a firearm, but that search occurred in an impounded vehiclenot a home. Cady repeatedly stressed the constitutional difference between vehicles and homes. Cady's reference to "community caretaking" arose in the context of police duties on public highways, such as aiding disabled motorists. That recognition did not create an open-ended license to perform caretaking tasks anywhere, including within the home.
What is reasonable for vehicles differs from what is reasonable for homes. This Court has repeatedly declined to expand exceptions to the warrant requirement to permit warrantless entry into the home. Accordingly, the judgment below is vacated and the case remanded for further proceedings consistent with this opinion.
It is so ordered.
Chief Justice ROBERTS, with whom Justice BREYER joins, concurring.
Fifteen years ago, this Court recognized that the role of a peace officer includes preventing violence and restoring order, not simply rendering first aid. A warrant to enter a home is not required when there is a need to assist persons who are seriously injured or threatened with such injury. Nothing in the Court's opinion limits that principle, and I join the opinion on that basis.
I join the opinion of the Court but write separately to explain my understanding of the holding and to highlight questions the Court does not decide. The Court holds that there is no special Fourth Amendment rule for a broad "community caretaking" category. The term describes many police tasks beyond criminal law enforcement, and because the category is broad, one should not assume the Fourth Amendment's reasonableness command applies the same way to everything that might be viewed as "community caretaking." Cady did not recognize any freestanding Fourth Amendment category; it used the phrase in passing.
While there is no overarching "community caretaking" doctrine, it does not follow that all searches and seizures conducted for non-law-enforcement purposes must be analyzed under the same Fourth Amendment rules developed in criminal cases. Those rules may or may not be appropriate in various non-criminal contexts; we do not decide that issue today.
This case falls within an important category: searches or seizures to prevent suicide. Assuming petitioner did not voluntarily consent to go with the officers for a psychological assessment, he was seized and subjected to a serious deprivation of liberty. We have addressed due-process standards for involuntary commitment but have not addressed Fourth Amendment restrictions on short-term seizures to ascertain imminent suicide risk. States have emergency-hold laws that vary widely; petitioner asked us to render a decision that could call features of these laws into question, and the Court appropriately refrains from doing so.
The case also implicates "red flag" laws that allow police to seize guns pursuant to a court order to prevent suicide or harm. These laws specify standards and procedures, and their provisions may be challenged under the Fourth Amendment. Our decision does not address those issues.
Another category concerns warrantless, nonconsensual searches of a home to determine whether a resident needs urgent medical attention and cannot summon help. At oral argument the Chief Justice posed a hypothetical of neighbors concerned about an elderly woman who failed to appear for dinner and did not answer calls. If the police entered without a warrant to check on her, would that violate the Fourth Amendment? Petitioner's position was that it would, even if 24 hours passed; he suggested that only a "warrant for a missing person" might later authorize entry. This highlights an important real-world problem: many people live alone, and elderly persons often fall or become incapacitated and cannot call for help. The chances for a good recovery may fade with each hour.
Current precedents do not address situations like this in all detail. The police may enter a home without a warrant when exigent circumstances exist, but exigency requires that there be insufficient time to get a warrant and warrants are not typically granted for checking a person's medical condition. Perhaps States should institute procedures for such warrants, but in the meantime courts must grapple with basic Fourth Amendment questions of reasonableness.
The illustrative categories discussed are not exhaustive. Searches and seizures for other non-law-enforcement purposes may present Fourth Amendment issues not settled today. In sum, the Court properly rejects the broad community-caretaking theory on which the decision below was based; the Court's decision goes no further, and on that understanding I join the opinion in full.
Additional notes and examples
I note some real-world examples. If a woman calls a hotline saying she is contemplating suicide and has firearms, and officers knock on her door and receive no response, exigent-circumstances principles permit entry because officers have an objectively reasonable basis to believe someone is at immediate risk. Similarly, if an elderly person is uncharacteristically absent and unresponsive, officers may enter to render aid if they have an objectively reasonable basis to believe the person is seriously injured or threatened with injury. The Fourth Amendment does not require officers to stand idly by as harm occurs. Courts and police must ensure actions in such cases are reasonable under the circumstances.
Justice KAVANAUGH, concurring.
I join the Court's opinion in full and write separately to emphasize that the decision does not prevent police officers from taking reasonable steps to assist persons inside a home who need aid. For example, officers may enter without a warrant where they reasonably try to prevent a potential suicide or to help an elderly person who has been out of contact and may have fallen and suffered serious injury.
The Fourth Amendment's ultimate touchstone is reasonableness. Ordinarily a warrant supported by probable cause is required to enter a home, but common-law analogies and a commonsense appraisal of reasonableness have produced recognized situations where a warrant is not required, including the exigent circumstances doctrine. That doctrine permits entry when the exigencies make the needs of law enforcement so compelling that a warrantless entry is objectively reasonable. One such exigency is the need to assist persons who are seriously injured or threatened with such injury.
The Court's exigency precedents allow warrantless entries when officers have an objectively reasonable basis to believe there is a current, ongoing crisis requiring immediate action. Officers do not need to show the harm has already occurred or is mere moments away; in cases involving suicide risk or an elderly person out of contact, it may be difficult or impossible to know with precision how imminent harm is. If someone is at risk of serious harm and it is reasonable for officers to intervene now, that is enough.
I offer a few non-exhaustive examples: if a person calls 911 saying she is contemplating suicide and has firearms and officers receive no response at the door, entry is permitted; if an elderly man is uncharacteristically absent and does not answer calls and officers reasonably fear he has fallen and is injured, entry to check on him is permitted. Courts, police departments, and officers must ensure that any actions are reasonable, but these examples illustrate warrantless entries that are constitutional under the exigent circumstances doctrine.
With those observations, I join the Court's opinion in full.