Case v. Montana

Overview

A case in which the Court held that law enforcement may enter a home without a search warrant when they have an objectively reasonable basis for believing that an occupant is seriously injured or faces imminent serious injury.

Facts

On September 27, 2021, William Trevor Case called his ex-girlfriend and threatened to kill himself. She heard what sounded like a gunshot and called 911. Officers responded to Case's Anaconda, Montana home, knocked, got no answer, saw him through a window alive but unresponsive, and entered. When they approached a bedroom closet, Case threw open the curtain holding what looked like a weapon. An officer shot him. A legal handgun was found nearby. Case was charged with assaulting a peace officer and moved to suppress all evidence from the warrantless entry.

Issue

Whether police officers conducting a welfare check may lawfully enter a home without a warrant after observing the occupant alive through a window but unresponsive, and whether such entry falls within the emergency aid exception to the Fourth Amendment's warrant requirement following Caniglia v. Strom.

Rule

The Fourth Amendment's protection of the home is at its apex. Warrantless entries are per se unreasonable absent an exception. The emergency aid exception permits warrantless home entry when officers have an objectively reasonable basis to believe an occupant is seriously injured or in imminent danger (Michigan v. Fisher, 558 U.S. 45 (2009)). Caniglia v. Strom, 593 U.S. 194 (2021), rejected a broad 'community caretaking' exception for residential entries, requiring that any warrantless entry into a home fall within a recognized categorical exception such as emergency aid, consent, or hot pursuit.

Analysis

Probable cause is a criminal investigation tool. It answers one question: is there reason to believe a crime occurred? That question has nothing to do with whether someone inside a home needs emergency help right now.

Montana required police to have probable cause before making a warrantless emergency entry. The problem is that probable cause was designed for a completely different situation. When officers respond to a 911 call about a possible suicide, they are not building a criminal case. They are trying to prevent a death. The question is not "did a crime happen" but "is someone in danger."

The Court called this a "transplant." Montana took a legal standard from one context and tried to apply it to another. Standards are built for specific questions. Transplanting them to different questions doesn't add protection, it adds confusion. Courts end up asking the wrong question in the name of rigor.

Justice Kagan's majority makes it simple: Brigham City's reasonableness standard "means just what it says, with no further gloss." No transplants. No extra requirements. Objectively reasonable basis to believe someone is seriously injured or imminently at risk. That is the test.

Conclusion

The Court unanimously affirmed Montana's judgment: the warrantless entry was lawful. But it scrapped Montana's reasoning. Probable cause is a criminal investigation standard. Emergency aid entries are governed by Brigham City v. Stuart's objective reasonableness test, and that standard was satisfied on these facts.

The practical result is a uniform national rule. Montana had been an outlier. Now it isn't.