In a major victory for the Second Amendment, the Supreme Court on Monday ruled 9-0 that Rhode Island police officers acted illegally when they seized a man’s guns without a warrant, which violated that man’s Fourth Amendment right. The SCOTUS decision overturned a 1st Circuit Court ruling that said police officers in the case were well within their right to confiscate that man’s firearms.
Police responded to a domestic violence call in 2015, at which point Edward Caniglia’s wife believed he was suicidal. He brought out a handgun, put it on the table, and instructed his wife to “shoot [him] and get it over with.” She ended up leaving for the night but had police conduct a welfare check after she failed to reach him, according to the court documents.
When the police arrived, Caniglia was sitting on the porch. He agreed to undergo a psychiatric evaluation under the condition that his firearms would not be seized. He was taken to a nearby hospital for evaluation, at which point police entered his home and confiscated two of his firearms. Caniglia’s firearms were confiscated without a warrant because he was deemed a threat to himself and others, according to the police.
Caniglia later sued the city of Cranston, Rhode Island, after police officers located and took his guns while he was in the hospital for a mental wellness check. He argued that the seizure violated his Fourth Amendment rights, although two federal courts ruled against him. Those courts relied on a provision of the law that allows police to seize guns from drivers while on the road. The case which they cited was Cady v Dombrowski. In that case, “an officer took a gun out of an impounded car without a warrant. The Supreme Court ruled at the time that police can conduct such warrantless searches if they are performing ‘community caretaking functions’ in a ‘reasonable’ manner,” TIME reported.
According to the Supreme Court, the Cady case is irrelevant to the Caniglia case and “is not an open-ended license to perform [the community caretaking functions] anywhere,” as Justice Clarence Thomas explained the Courts view in the opinion:
Neither the holding nor logic of Cady justifies such warrantless searches and seizures in the home. Cady held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment. In reaching this conclusion, the Court noted that the officers who patrol the “public highways” are often called to discharge noncriminal “community caretaking functions,” such as responding to disabled vehicles or investigating accidents. But searches of vehicles and homes are constitutionally different, as the Cady opinion repeatedly stressed. The very core of the Fourth Amendment’s guarantee is the right of a person to retreat into his or her home and “there be free from unreasonable governmental intrusion.” A recognition of the existence of “community caretaking” tasks, like rendering aid to motorists in disabled vehicles, is not an open-ended license to perform them anywhere.
The American Civil Liberties Union (ALCU), the American Conservative Union (ACU), and the Cato Institute filed a joint amicus curiae brief in the case, arguing against the Cady application in the case.
“The Fourth Amendment does not permit such a freewheeling balancing inquiry when it comes to searches of homes,” the join brief explained. “… Given the capacious array of activities that could be called “community caretaking,” it is hardly surprising that courts have relied on it to uphold warrantless entries based on a wide variety of police actions.”
Justice Samuel Alito noted in a concurring opinion that some of the principles of Caniglia’s case could apply to rulings on red flag laws, which allow police to seize guns owned by individuals deemed dangerous to themselves or others. “Provisions of red flag laws may be challenged under the Fourth Amendment, and those cases may come before us. Our decision today does not address those issues,” he wrote.