Caniglia v. Strom

Whether the “community caretaking” exception to the Fourth Amendment’s warrant requirement extends to the home.

Petitioner’s firearms were seized after police officers entered his home. Petitioner brought several claims in federal district court, and argued that the officers’ entrance into his home and subsequent seizures without a warrant violated the Fourth Amendment. The officers claimed that they were acting in a “community caretaking” capacity because the responded to a scene with a mentally unstable individual, not investigating a crime. The district court held that the warrantless entry and seizures were covered by the “community caretaking” exception and did not violate Petitioner’s Fourth Amendment rights. The First Circuit affirmed. The issue on appeal is whether the “community caretaking” exception, first articulated in Cady v. Dombrowski, 413 U.S. 433 (1973), extends to the home. Petitioner argues that “vehicle-specific doctrines do not apply outside of that context.” Petitioner contends that Fourth Amendment special protections afforded to the home is consistent with restricting the community caretaking exception to searches of vehicles. Petitioner also argues that the reasonable expectation of privacy in vehicles, which “are near the very bottom of the Fourth Amendment pile,” is significantly less than the expectation relating to one’s home.