Supreme Court Sides With Man Fighting Gun Seizure After Mental Health Episode

Biden administration split with progressive groups, defended cops

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May 17, 2021

The Supreme Court on Monday sided with a Rhode Island man who sued police officers for entering his home, seizing his guns, and sending him for a psychiatric evaluation without a warrant while conducting a wellness check.

The justices wiped out an appeals court ruling that favored the officers, saying the appeals court was wrong to authorize a "community caretaking" exception to the Fourth Amendment's warrant requirement. Justice Clarence Thomas delivered the decision for a unanimous Court.

Monday's case, which also implicated gun rights and rose amid nationwide anti-police protests, divided usual left-wing allies. The Biden administration, which gun groups say has not done enough on gun control, argued in support of the officers. The ACLU supported the Rhode Island man before the High Court, claiming the administration's position would lead to unconstitutional privacy violations.

"For years, lower courts have punched holes in the right of Americans to turn government agents away from their homes under a doctrine called the 'community caretaking exception,'" said Daniel Woislaw of the Pacific Legal Foundation, which backed the Rhode Island man in Monday's case. "The Supreme Court soundly rejected this doctrine today."

The plaintiff, Edward Caniglia of Cranston, R.I., had a heated argument with his spouse in August 2015 that set off the dispute. During the exchange, Caniglia placed his handgun on their dining room table and said, "Why don't you just shoot me and get me out of my misery?" His wife spent the evening in a hotel and asked police to check on his welfare the following day.

The responding officers called an ambulance to take Caniglia for a psychiatric evaluation. Caniglia later said he agreed to go on the condition that the officers would not take his firearms, but police took both his handguns shortly after he left. He was discharged from the hospital on the same day.

In turn, Caniglia filed a lawsuit and argued police violated his constitutional rights by taking his guns and sending him to the hospital without a warrant. The First U.S. Circuit Court of Appeals said there were no constitutional violations. Police officers, they said, "provide an infinite variety of services to preserve and protect community safety" without warrants that are fully consistent with the Constitution.

Thomas said the appeals court went too far in recognizing a "community caretaking" exception to the usual rule that police need a court order to search a home or take someone's property.

"The First Circuit’s 'community caretaking' rule, however, goes beyond anything this Court has recognized," Thomas wrote.

In three separate opinions, several members of the Court emphasized that the decision does not hamstring police officers conducting wellness checks or responding to mental health emergencies. Those situations, they explained, are covered by other Fourth Amendment exceptions. The problem in Monday's case, they said, is that the First Circuit's decision gave police too much leeway.

Justice Brett Kavanaugh wrote that nothing in Monday's decision would prevent an officer from entering a home if he has reason to believe there is an ongoing crisis. Chief Justice John Roberts made a similar point in his own concurrence.

"If someone is at risk of serious harm and it is reasonable for officers to intervene now, that is enough for the officers to enter," Kavanaugh wrote.

Justice Samuel Alito suggested that the states should create procedures for speedy issuance of a warrant to check on a person's well-being. Other members of the Court proposed the same during oral arguments in March. He also said that the constitutionality of so-called red flag laws, which allow law enforcement to seize firearms in an emergency, is still an open question.

"Provisions of red flag laws may be challenged under the Fourth Amendment, and those cases may come before us," Alito wrote. "Our decision today does not address those issues."

The case is No. 20-157 Caniglia v. Strom.

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