Civil and Human Rights

Caniglia v. Strom

In Caniglia v. Strom, the Supreme Court held that the “community caretaking” exception to the Fourth Amendment’s warrant requirement does not extend to the home.

Case Summary

In Cady v. Dombrowski, the Supreme Court held that under certain circumstances, police may search a motor vehicle without first obtaining a warrant if they are engaged in a “community caretaking” function—that is, some duty wholly divorced from the investigation of a crime or enforcement of the criminal laws.  The Court made clear, however, that the exception applied only to motor vehicles and did not extend to people’s homes.  Despite the clear line drawn by the Court, numerous lower courts have extended the community caretaking exception to allow warrantless entries into, and seizures from, people’s homes.

In this case, police officers entered the home of Edward A. Caniglia without a warrant and conducted a search and seizure.  Caniglia sued, alleging the officers had violated, among other things, his Fourth Amendment right to be secure in his home.  The U.S. Court of Appeals for the First Circuit upheld the warrantless search and seizure, thus joining those courts which have extended Cady’s community caretaking exception to the home.  Caniglia asked the Supreme Court to hear his case, and the Court agreed to do so.  CAC filed an amicus curiae brief in support of Caniglia, urging the Supreme Court to reverse the ruling of the First Circuit.

Our brief made two principal arguments.  First, our brief described the primacy of the home in the text and history of the Fourth Amendment.  British common law widely recognized the sanctity of the home and severely limited the circumstances in which a home could be entered and searched without a warrant.  The adage “a man’s house is his castle” was not merely a turn of phrase, but an important legal maxim.  The Fourth Amendment incorporated that maxim but also extended it, providing broad protections against unbridled search and seizure in response to the specific abuses the colonists suffered under British rule—namely, the use of general warrants and “writs of assistance” that lacked specificity as to the person and place to be searched and were not based on any individualized suspicion of criminal wrongdoing.

Second, our brief argued that the decision of the First Circuit to extend the community caretaking exception to the home cannot be squared with these core principles.  The decision below failed to recognize the important constitutional difference between cars and homes, undervaluing the sanctity of the home reflected in the text and history of the Fourth Amendment and untethering the community caretaking exception from its justifications.  Moreover, we argued that “community caretaking” is a broad and nebulous interest not subject to any meaningful limiting principle and that allowing the police to invade people’s homes on such an open-ended rationale would invite police to abuse their power in a manner that the Fourth Amendment was specifically designed to guard against.

In May 2021, the Court unanimously held that the “community caretaking” exception in Cady does not justify the creation of a standalone doctrine allowing for warrantless searches and seizures in the home.  Emphasizing Cady’s “unmistakable distinction between vehicles and homes,” the Court concluded that “[w]hat is reasonable for vehicles is different from what is reasonable for homes.”  Accordingly, the Court ruled in favor of Caniglia and vacated the judgment of the First Circuit.

Case Timeline

  • January 15, 2021

    CAC files amicus curiae brief

    Sup. Ct. Amicus Br.
  • March 24, 2021

    The Supreme Court hears oral argument

  • May 17, 2021

    The Supreme Court issues its decision

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