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Caniglia v. Strom
United States Supreme Court
141 S. Ct. 1596 (2021)
During an argument, Edward Caniglia (plaintiff) placed a handgun on the dining room table and asked his wife to shoot him. Mrs. Caniglia refused and left the home for the night. The next morning, Mrs. Caniglia was unable to contact Edward. Mrs. Caniglia then requested that police officers (defendants) accompany her to the Caniglias’ home to conduct a welfare check on Edward. Mrs. Caniglia and the police officers found Edward on the porch, unharmed. Edward stated he was not suicidal but agreed to undergo a psychiatric evaluation after police allegedly promised not to confiscate his firearms. The police believed Edward was a risk to himself and others. Mrs. Caniglia guided police into the home, after allegedly being misinformed regarding Edward’s wishes, and allowed police to seize Edward’s firearms. Edward sued the police officers, arguing that the officers violated his Fourth Amendment rights by entering the home and seizing both Edward and his firearms without a warrant. The police officers did not prove they had consent and forfeited the point regarding whether exigent circumstances justified the warrantless search and seizure. It was undisputed that the police did not have a warrant. The First Circuit held that the police were authorized to enter the home without a warrant pursuant to the officers’ community-caretaking powers. Edward appealed.
Rule of Law
Holding and Reasoning (Thomas, J.)
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