In 1973 an officer removed a gun from an impounded car without a warrant. This became the case for Cady v. Dombrowski and led to the creation of the “Community Caretaking” exception in the 4th amendment. The case reached the Supreme Court and it determined that a warrantless search can be conducted in “community care functions” within a “reasonable” manner.
The “community caretaking” exception was utilized in Cranston, New Jersey in 2015 when the Cranston police were called to the home of Edward Caniglia by Caniglia’s wife who feared for his safety. Caniglia agreed to go to the hospital for a psychiatric evaluation on the condition that the police would not confiscate his guns from his home. He was not committed to the hospital. While being evaluated at the local hospital the ranking officer, with approval from his direct supervisor, confiscated two of Caniglia’s guns. This warrantless act by the police led to the case Caniglia v. Strom.
Edward Caniglia attempted to retrieve his firearms from the Cranston, New Jersey police department multiple times over three months and it wasn’t until his attorney filed a formal complaint that his firearms were returned. Caniglia then filed a lawsuit claiming infringements on his 2nd and 4th amendment rights. The case was heard by the district court and summary judgment was granted to the defendants. Caniglia appealed the verdict, and the case was taken to the First Circuit who upheld the decision of the lower court. The case then proceeded to the Supreme Court.
In a 9-0 ruling the Supreme Court determined that the 4th Amendment exception of “community caretaking” does not apply in the manner of personal dwellings such as a house. This decision reaffirms the Fourth Amendment protections for personal dwellings. In the majority opinion Justice Clarence Thomas wrote, “the Fourth Amendment protects ‘[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.” Justice Clarence Thomas, in the majority opinion, did recognize that in modern society police perform many civil tasks, however recognition of this is not an “open-ended license to perform them anywhere.”
Civil liberty advocates were highly focused on this decision as it would have created a potentially dangerous situation if the decision had gone in Strom’s favor. Giving law enforcement the precedent to enter homes and seize property without warrant or probable cause.
The decision in favor of Caniglia comes during a highly tumultuous political time where there is national debate on the extent and reach of law enforcement. The decision is seen as victory for those who believe that we as a society need to dial back the scope of police activity. Clark Neily of the Cato Institute stated, “This represents a welcome, albeit unusual, refusal on the justices’ part to give the government greater leeway in conducting warrantless searches of people’s homes and personal effects.”
Caniglia v. Strom had vast implications for our society as a whole. The 9-0 decision reaffirms the importance of the 4thAmendment and the protections it provides. Beyond that, the Supreme Court’s decision during this politically volatile time gives hope to Civil Liberty advocates.