Caniglia v. Strom et al.

The “community caretaking exception” to warrantless searches articulated in Cady v. Dombrowski does not apply to homes, because there is a constitutional difference between vehicles and homes.

Petitioner appealed a grant of summary judgment following the seizure of firearm. Petitioner argued that police violated his Fourth Amendment’s rights by entering his home without warrant. The First Circuit affirmed the grant of summary judgement, reasoning that the police were justified in the warrantless search under a “community caretaking exception” established in Cady v. Dombrowski, 413 U.S. 433 (1973). On appeal, the Supreme Court held that Cady did not apply in the case at bar. Reasoning that the exception articulated in Cady applied solely to searched of vehicles often completed by officers who patrol “public highways.” The Court held that neither the holding nor the logic of Cady justified warrantless search of Petitioner’s home, reasoning that there is a constitutional difference between vehicles and homes. The First Circuit’s application of Cady violated Supreme Court precedent, as the Court has repeatedly “declined to expand the scope of . . . exceptions to the warrant requirement to permit warrantless entry into the home.” Collins v. Virginia, 584 U.S., at ___ (slip op., at 8). (2018). What is reasonable for vehicles is different from what is reasonable for home. Vacated and remanded.