Case v. Montana
The Court holds that the objective-reasonableness standard it set in Brigham City v. Stuart governs warrantless home entries to render emergency aid, and that it applies without any further gloss. Officers need not have probable cause to believe an emergency is occurring; they may enter when they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury — a standard the officers here satisfied.
Case background
Montana police officers responded to the home of petitioner William Case after his ex-girlfriend called 9-1-1 to report that he was threatening suicide and may have shot himself. The officers knocked on the doors and yelled into an open window but got no response; they could see an empty handgun holster and something that looked like a suicide note inside, and they ultimately decided to enter the home to render emergency aid. When one officer approached a bedroom closet in which Case was hiding, Case threw open the closet curtain while holding an object that looked like a gun, and, fearing that he was about to be shot, the officer shot and injured Case. Officers later found a handgun next to where Case had stood. Case was charged with assaulting a police officer and moved to suppress all evidence obtained from the home entry, arguing that the police violated the Fourth Amendment by entering without a warrant. The trial court denied the motion, a jury found Case guilty, and a divided Montana Supreme Court upheld the officers’ entry as lawful under Montana’s caretaker doctrine, rejecting the contention that an officer must have probable cause to believe that an occupant needs emergency aid.
Questions Presented
(1) Whether law enforcement may enter a home without a search warrant based on less than probable cause that an emergency is occurring, or whether the emergency-aid exception requires probable cause.
Holding
Brigham City’s objective-reasonableness standard for warrantless home entries to render emergency aid applies without further gloss, and it was satisfied in this case. The probable-cause requirement is rooted in, and derives its meaning from, the criminal-investigation context, and the Court declined to transplant it onto the emergency-aid exception. Officers may enter a home without a warrant when they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury. The information the officers obtained from Case’s ex-girlfriend, combined with their observations at the scene, gave them just such a basis to believe that Case may already have shot himself or would do so absent intervention, so the Court affirmed the judgment — though not all the reasoning — of the Montana Supreme Court.
The Court
Justice Kagan delivered the opinion for a unanimous Court. Justice Sotomayor and Justice Gorsuch each filed concurring opinions.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in Case v. Montana, written by Justice Kagan.
AI disclosure: The voice in this episode is AI-generated, using a machine learning model styled to loosely resemble the authoring justice. Tone, inflection, pacing, and emphasis are artifacts of the model and should not be attributed to Justice Kagan. The text being read is the Court’s published majority opinion, lightly adapted to improve readability for the spoken format.