US Supreme Court Clarifies Standard for Warrantless Home Entries During Emergencies: Reasonable Basis, Not Probable Cause, is Required
Criminal Defense Lawyer Zak T. Goldstein, Esquire
The Supreme Court of the United States has issued a unanimous decision in Case v. Montana, settling a disagreement among lower courts about when police may enter a private home without a warrant to provide emergency assistance.
In an opinion authored by Justice Kagan, the Court held that police do not need probable cause to enter a home to render emergency aid. Instead, officers only need an “objectively reasonable basis” for believing that an occupant is seriously injured or imminently threatened by such injury. This ruling reinforces the standard previously set in Brigham City v. Stuart and rejects the argument that the arguably higher “probable cause” standard used in criminal investigations should apply to emergency aid situations.
The Facts of the Case
The case arose from a domestic disturbance in Montana. The petitioner, William Case, allegedly called his ex-girlfriend and threatened to kill himself. During the call, she heard what sounded like a gun cocking, followed by a “pop” and then silence. She immediately called 911 and drove to his home.
The police drove to the home, as well. When police officers arrived, they knocked on the doors and yelled into an open window but received no response. Peering inside with flashlights, they saw an empty handgun holster and a notepad that appeared to contain a suicide note. Concerned that Case might have shot himself and was bleeding out, the officers decided to enter the home without a warrant to render emergency aid.
Upon entering a bedroom, Case emerged from a closet holding an object that looked like a gun. An officer, fearing for his safety, shot and injured Case. Case survived and was subsequently charged with assaulting a police officer. He moved to suppress the evidence obtained during the entry, arguing that the warrantless entry violated his Fourth Amendment rights.
The Legal Issue on Appeal: Probable Cause vs. Reasonable Basis
The Fourth Amendment generally protects the home from warrantless searches and seizures. However, there are exceptions, including the “emergency aid” exception.
The legal dispute in Case v. Montana centered on the standard of proof required for this exception. Case argued that because the home is constitutionally protected, officers should be required to have probable cause to believe an emergency exists. Probably cause is the same standard used for criminal warrants.
The Montana Supreme Court had upheld the entry but used a “community caretaker” doctrine that resembled a lower “reasonable suspicion” standard often used for street stops and car searches such as Terry frisks. The defendant appealed to the U.S. Supreme Court, asking the Justices to impose the stricter probable cause requirement.
The Supreme Court’s Decision
The Supreme Court unanimously rejected the application of the probable cause standard to emergency aid cases. Justice Kagan explained that the concept of “probable cause” is “peculiarly related to criminal investigations” and assesses the likelihood of finding evidence of a crime.
The Court held that transplanting criminal law standards into a non-investigatory, lifesaving context makes little sense. Instead, the Court reaffirmed the rule from Brigham City v. Stuart: officers may enter a home without a warrant if they have an “objectively reasonable basis for believing” that an occupant is seriously injured or imminently threatened.
Applying this standard to the facts, the Court found the officers’ entry was lawful. The combination of the specific suicide threat, the “pop” heard over the phone, and the visual observation of the empty holster and suicide note gave officers a reasonable basis to believe Case needed immediate medical attention.
Key Takeaways
This decision provides clarity for both law enforcement and defense attorneys regarding the “emergency aid” exception:
Distinct from Criminal Investigation: The Court firmly separated emergency aid entries from criminal investigations. The higher “probable cause” standard does not apply when the primary purpose is saving lives, not gathering evidence.
Limited Scope of Entry: Importantly, the Court noted that this exception is not an open invitation to search. An emergency aid entry “provides no basis to search the premises beyond what is reasonably needed to deal with the emergency.” If police enter to check on a suicidal person, they cannot start rummaging through drawers for drugs unless those drawers are relevant to the emergency.
Community Caretaking Clarified: The Court criticized the lower court's reliance on the “community caretaker” doctrine, reiterating that broad community caretaking duties do not justify warrantless home entries on their own; there must be an actual exigency or emergency.
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Philadelphia Criminal Defense Lawyer Zak Goldstein
If you are facing criminal charges or under investigation by the police, we can help. We have successfully defended thousands of clients against criminal charges in courts throughout Pennsylvania and New Jersey. We have successfully obtained full acquittals and dismissals in cases involving charges such as Conspiracy, Aggravated Assault, Rape, Violations of the Uniform Firearms Act, and First-Degree Murder. We have also won criminal appeals and PCRAs in state and federal court, including the successful direct appeal of a first-degree murder conviction and the exoneration of a client who spent 33 years in prison for a murder he did not commit. Our award-winning Philadelphia criminal defense lawyers offer a free criminal defense strategy session to any potential client. Call 267-225-2545 to speak with an experienced and understanding defense attorney today.
