SCOTUS Finds Police Properly Entered Man’s Home Despite Absence Of Warrant
The U.S. Supreme Court on Tuesday unanimously upheld the conviction of a Montana man who assaulted a police officer, ruling that law enforcement did not violate the Fourth Amendment when officers entered his home without a warrant during an apparent mental-health emergency.
In Case v. Montana, Justice Elena Kagan authored the Court’s opinion, rejecting claims by William Case that police officers in Anaconda, Montana, were constitutionally required to establish “probable cause” before entering his residence.
The case arose after Case’s former girlfriend contacted authorities in 2021, warning that he had threatened to kill himself and to shoot any officers who attempted to intervene. Following the 911 call, three officers were dispatched to check on what was described as a “suicidal male.”
When officers arrived, they received no response after knocking on the door and calling out through an open window. From outside the home, they observed empty beer cans, an empty handgun holster, and what appeared to be a suicide note. Police were also aware of Case’s prior threats of self-harm and believed at one point that he may have been attempting to provoke a lethal confrontation with law enforcement.
Approximately 40 minutes after arriving, officers entered the home. Case was found hiding in an upstairs bedroom closet holding a black object officers believed to be a firearm. One officer shot Case in the stomach, and another later recovered a gun from a nearby laundry basket.
Case sought to suppress the evidence discovered inside the home, arguing that the officers’ warrantless entry violated the Constitution. Montana courts rejected that argument, prompting an appeal to the nation’s highest court.
Before the Supreme Court, Case contended that officers must have “probable cause to believe someone is in urgent need of help” to justify entering a home without a warrant under the emergency-aid exception.
The Court disagreed.
In her 11-page opinion, Kagan emphasized that the Fourth Amendment protects against “unreasonable searches and seizures,” noting that the home occupies a central place in constitutional protections.
“As a general rule,” she wrote, “When the intrusion is into that most private place, ‘reasonableness’ usually means having a warrant.”
However, she explained that longstanding exceptions exist, including situations involving “the need to provide an occupant with emergency aid.”
Kagan pointed to the Court’s 2006 decision in Brigham City v. Stuart, where officers were permitted to enter a home without a warrant after witnessing a violent altercation through a window. In that case, the Court held the entry was justified because “[t]he officers had ‘an objectively reasonable basis for believing that an occupant [was] seriously injured or imminently threatened with such injury.’”
Applying that same standard, Kagan concluded that Case’s conviction was lawful. At the time of entry, officers had “an ‘objectively reasonable basis for believing’ that their intervention was needed to prevent serious harm.”
Justice Sonia Sotomayor wrote a concurring opinion highlighting broader concerns surrounding police encounters with individuals experiencing mental-health crises. She noted that “individuals with serious mental-health conditions are disproportionately likely to be injured and seven times more likely to be killed during police interactions compared to the general population.”
Sotomayor suggested that “in some circumstances it may be more reasonable for officers to try different means of de-escalation before entering the home of a person experiencing a mental-health crisis.” Still, she agreed the officers acted reasonably here, writing that the facts, “[c]onsidered together,” “gave rise to an objectively reasonable basis for the officers to believe that Case was already injured and in need of emergency medical assistance, and was not necessarily waiting inside for the officers seeking to provoke an escalation leading to suicide-by-cop.”
Justice Neil Gorsuch also concurred, focusing on the historical roots of the emergency-aid doctrine. He traced the exception to judge-made law that, he wrote, “has generally permitted a private citizen to enter another’s house and property in order to avert serious physical harm.”
Under that same legal tradition, Gorsuch observed, law enforcement “officers generally enjoy the same legal privileges as private citizens.”
The ruling reinforces long-recognized limits on the Fourth Amendment while affirming that police officers—operating under the rule of law during President Donald J. Trump’s second term—retain the authority to act swiftly when lives are at risk.