Caniglia v. Strom was argued on March 24, 2021 via telephone with live audio. It was decided on May 17, 2021.
This case asks the following important question: Does the “community caretaking” exception to the Fourth Amendment’s warrant requirement extend to the home?
Edward Caniglia had no criminal history, no record of violence, no gun violations, and had never been known to self harm. In August 2015 he had a heated argument with his wife, Kim, in their home in Cranston, Rhode Island. As the argument worsened, he went to their bedroom, and returned with his unloaded handgun. He put the gun on the table and said to his wife, “Why don’t you just shoot me and get me out of my misery?” Mrs. Caniglia decided to go to a motel for the night.
The next day, Mrs. Caniglia called home. When her husband did not answer, she became worried and called the police to ask that they make a “well call” to check on him and escort her home. Mrs. Caniglia told the officers about the argument, explained the reasons she was concerned for her husband’s safety, and told them he could be suicidal.
Officers believed there was a possibility Mr. Caniglia might self-harm, so an officer told Mr. Caniglia he was taking him to a hospital for a psychiatric evaluation. Mr. Caniglia was examined by a physician, a nurse, and a social worker and was discharged.
While Mr. Caniglia was at the hospital, officers entered the home to seize the handguns because they feared he might harm himself or others. Earlier, Mr. Caniglia told them, “You’re not confiscating anything.” The officers lied to Mrs. Caniglia telling her that husband consented. Based on that, Mrs. Caniglia took the officers to the bedroom and garage where the guns were located. The officers seized the guns.
The Caniglias asked for the guns back on several occasions, but the police refused. Mr. Caniglia alleged that the city violated his rights under the Second Amendment (right to bear arms), Fourth Amendment (unreasonable search and seizure), and the 14th Amendment’s Due Process and Equal Protection Clauses. After he filed the lawsuit, his guns were returned. The District Court found for Mr. Caniglia on the 14th Amendment Due Process Clause claim because the city had no process for recovering his guns after they had been seized. It found against Mr. Caniglia on all his other claims. It stated that the community caretaking services the police provide could be required in homes as well as vehicles and that this exception to the Fourth Amendment justified the warrantless entry and seizures of the guns.
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