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Community Caretaking Exception to the Warrant Requirement and the Home

Case Name: Caniglia v. Strom (2021) __ U.S. __ [141 S.Ct. 1596]
Case #: 20-157
Last Updated: May 17, 2021

Whether the “community caretaking” exception to the Fourth Amendment’s warrant requirement extends to the home.


Decades ago, this Court held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment. Cady v. Dombrowski, 413 U. S. 433, 93 S. Ct. 2523, 37 L. Ed. 2d 706 (1973). In reaching this conclusion, the Court observed that police officers who patrol the “public highways” are often called to discharge noncriminal “community caretaking functions,” such as responding to disabled vehicles or investigating accidents. Id., at 441, 93 S. Ct. 2523, 37 L. Ed. 2d 706. The question today is whether Cady’s acknowledgment of these “caretaking” duties creates a standalone doctrine that justifies warrantless searches and seizures in the home. It does not.

As a result, the “community caretaking” exception did not justify the warrantless seizure of Caniglia’s firearms from his home after he was taken to the hospital for a psychiatric evaluation.

This case was decided 5/17/2021.

Justice Thomas delivered the opinion for a unanimous court. Chief Justice Roberts filed a concurring opinion, in which Justice Breyer joined. Justices Alito and Kavanaugh filed concurring opinions.

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