Supreme Court Finds No Fourth Amendment Violation in Warrantless Entry to Home
The U.S. Supreme Court issued an opinion today in Case v. Montana, rejecting an argument that police officers must have "probable cause" to enter a home without a warrant when they encounter an emergency situation. The Court held that the proper test for the emergency exception to the warrant requirement is whether the officer was acting on an objective, reasonable belief that someone inside the home was seriously injured, imminently threatened with an injury, or needed emergency assistance, rather than the "probable cause" standard that applies in criminal cases.
In this case, petitioner's ex-girlfield called police to report that petitioner had been drinking and was threatening suicide. Police officers were dispatched to do a welfare check and when they arrived, determined that the situation was serious and decided to enter the home to render emergency aid. An officer encountered the petitioner holding a black object that the officer thought was a gun, and the officer fired his own rifle. The petitioner was ultimately charged with assaulting a police officer after a handgun was found next to where petitioner stood. Petitioner filed a motion to suppress the evidence at trial, arguing that police had violated his Fourth Amendment rights by entering his home without a warrant. The trial court denied the motion, finding that officers were responding to an emergency (an exception to the warrant requirement).
The case was appealed and made its way to the U.S. Supreme Court, which upheld the trial court's ruling. The Court rejected petitioner's argument that the police officers had to show "probable cause" in order to exercise a warrantless search. Instead, officers must show that they had an "objectively reasonable basis for believing" that their intervention was necessary to prevent serious harm. Here, the officers demonstrated that they were aware of petitioner's mental health and alcohol abuse problems and that he had previously talked about committing suicide. They had statements from his ex-girlfriend that he had threatened to kill himself, and when they went to the home, he refused to respond to their knocking on his door. The Court found that it was objectively reasonable for the officers to believe petitioner needed emergency aid, so there was no Fourth Amendment violation of his rights in the warrantless entry.
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