The U.S. Supreme Court agreed with the conviction of a Montana man who hit a police officer. Justice Elena Kagan wrote the unanimous opinion for the court in Case v. Montana. The court said that police officers in Anaconda, Montana, did not break the Fourth Amendment when they entered William Case’s home without a warrant.
The court rejected Case’s argument that the police officers needed “probable cause” to go into his house.
Kagan said that in previous Supreme Court cases, it was enough for the police officers to have a good reason to think that Case, whose ex-girlfriend had called them to say he was going to kill himself, needed help right away.
In 2021, Case told his ex-girlfriend, whose initials are J.H., that he was going to kill himself and shoot any police officers who came to his house. J.H. called 911, which sent three police officers to check on a “suicidal male.”
When police officers knocked on the door and yelled through an open window, Case didn’t answer. However, the officers saw empty beer cans, an empty handgun holster, and what they thought was a suicide note in the house. The police also knew that Case had threatened to kill himself before. At one point, they thought he was trying to get them to shoot him.
The police officers went into the house about 40 minutes after they got there. Case was hiding in a closet in an upstairs bedroom with a black object that police thought was a gun. One officer shot Case in the stomach, and another officer found a gun in a laundry basket near Case.
Case told the trial court that the evidence that police officers found after they entered his house should not be used because they should have had a warrant. But the state courts didn’t agree with that, so Case went to the Supreme Court.
Case said that police officers must have “probable cause to believe someone is in urgent need of help” if they go into a home without a warrant to help someone in an emergency.
The Supreme Court did not agree.
Kagan wrote an 11-page opinion in which he said that the Fourth Amendment protects people from “unreasonable searches and seizures” and that the sanctity of the home is at the heart of the amendment.
As a general rule, Kagan explained, “When the intrusion is into that most private place, ‘reasonableness’ usually means having a warrant.”
But there are exceptions to that general rule, she continued, including “the need to provide an occupant with emergency aid.”
Two decades ago, the Supreme Court ruled in Brigham City v. Stuart that police officers could enter a home without a warrant if they were responding to a noise complaint.
They saw a fight between a teenager and several adults through a window in the kitchen when they got there.
The court ruled that the warrantless entry was “reasonable under the circumstances,” Kagan explained, because “[t]he officers had ‘an objectively reasonable basis for believing that an occupant [was] seriously injured or imminently threatened with such injury.’”
When the Brigham City test is applied to this case, Kagan concluded, Case’s conviction can stand. When they entered Case’s home, she said, the police officers had “an ‘objectively reasonable basis for believing’ that their intervention was needed to prevent serious harm.”
Justice Sonia Sotomayor penned a concurring opinion in which she emphasized 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.”
Therefore, she said, “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.” But in this case, 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 wrote a concurring opinion, in which he focused on the origins of the emergency-aid exception. He located the exception in judge-made law – which, he said, “has generally permitted a private citizen to enter another’s house and property in order to avert serious physical harm.”
And under that law, he observed, law enforcement “officers generally enjoy the same legal privileges as private citizens.”
