In an important victory for privacy rights, the U.S Supreme Court today unanimously rejected police arguments that engaging in a non-criminal “community caretaking” function allows them to search a person’s home without a warrant. The American Civil Liberties Union of Rhode Island had filed a “friend of the court” brief before the Court, and had represented the petitioner in the case in prior proceedings, arguing that an unfavorable ruling in the case could “give police free rein to enter the home without probable cause or a warrant, whenever they think it is ‘reasonable’ to do so.” Today’s court decision averts that prospect.
The case, dating back to 2015, involves Cranston resident Edward Caniglia, whose two lawfully owned firearms were seized from his home without a warrant or his consent in a non-emergency situation as a result of a “wellness check” conducted by Cranston police officers. His wife had called the police department to express concern about his mental health in response to an argument they had had the night before.
When officers arrived at his house the day after that argument, they told Caniglia that his firearms would be confiscated unless he agreed to a mental health evaluation. Caniglia agreed, and was transported by ambulance to Kent Hospital where he was evaluated and promptly released. However, despite their assurances to the contrary, police officers entered Caniglia’s home in the meantime and confiscated his two firearms and ammunition for “safekeeping.” The officers told Caniglia’s wife that once he was cleared by the hospital, he could pick up them up at the station. But when Caniglia tried to do so, he was told it was department policy not to return weapons confiscated for safekeeping without a court order.
ACLU cooperating attorneys Thomas Lyons and Rhiannon Huffman filed a federal lawsuit against the Cranston Police Department, challenging both the seizure of his weapons without a warrant and the department policy against returning them without a court order. The federal district court agreed that the department’s policy of refusing to return the firearms was unconstitutional, but upheld the warrantless search and seizure of the weapons on the grounds that police were engaged in a “community caretaking” function that did not require a warrant. The federal court of appeals upheld that ruling.
Relying on private counsel, Caniglia appealed to the Supreme Court, which agreed to hear his case to decide whether the “community caretaking” exception to the Fourth Amendment’s warrant requirement – an exception that arose in Supreme Court jurisprudence specifically involving the searches of cars impounded by the police – can be applied to warrantless searches of a person’s home. Today it ruled, in a brief unanimous opinion by Justice Clarence Thomas, that it does not, stating that “[w]hat is reasonable for vehicles is different from what is reasonable for homes.” The court’s decision reverses the lower court decisions to the contrary.
ACLU of Rhode Island executive director Steven Brown said today: “Today’s court decision is an extremely important victory for privacy rights. The Fourth Amendment has always served as an important barrier to police intrusion into the home, and we are very pleased that the Court reaffirmed this fundamental principle.”
In addition to the ACLU of Rhode Island and its National office, the ACLU’s amicus brief was filed on behalf of three conservative organizations: the Cato Institute, the American Conservative Union Foundation, and the R Street Institute.
More information about the case can be found here.
