Case v. Montana: U.S. Supreme Court Addresses “Community Caretaking” Exception To The Warrant Requirement

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In Case v. Montana, No. 24-624 (January 14, 2026), the U.S. Supreme Court unanimously (!) decided an interesting criminal case regarding the limits of the Community Caretaking Exception to warrant requirement. In short, Case v. Montana held that a police officer does not need Probable Cause or Reasonable Suspicion to believe an occupant is in need of emergency aid to enter a home without a warrant to render assistance.  Those standards are related to criminal investigations.  An officer need only have an “objectively reasonable basis” to believe that an occupant is seriously injured or imminently threatened with such an injury to justify a warrantless intrusion.

FACTUAL BACKGROUND

In this case, Montana police officers responded to the home of William Case after his ex-girlfriend called 911 to report that he was threatening suicide and may have shot himself. The officers knocked on the doors and yelled into an open window, but got no response. They could see an empty handgun holster and something that looked like a suicide note inside, and they ultimately decided to enter the home to render emergency aid. When one officer approached a bedroom closet in which Case was hiding, Case threw open the closet curtain while hold ing an object that looked like a gun. Fearing that he was about to be shot, the officer shot and injured Case. An ambulance was called to take Case to the hospital, and officers found a handgun next to where Case had stood.

Mr. Case was charged with assaulting a police officer. Case moved to suppress all evidence obtained from the home entry. He argued that the police violated the Fourth Amendment by entering without a warrant. The trial court denied the motion, and a jury found Case guilty. A divided Montana Supreme Court upheld the officers’ entry as lawful under Montana’s Community Caretaker Doctrine, rejecting the contention that an officer must have probable cause to believe that an occupant needs emergency aid.

COURT’S ANALYSIS & CONCLUSIONS

The United States Supreme Court (hereinafter, “The Court”) began with a stare decisis analysis of Brigham City v. Stuart. In that case, the Court held that the Fourth Amendment allows police officers to enter a home without a warrant if they have an “objectively reasonable basis for believing” that someone inside needs emergency assistance. Applied here, the U.S. Supreme Court reasoned that Brigham City’s standard of review was satisfied in this case.

Next, the Court reasoned that although searches and seizures inside a home without a warrant are presumptively unreasonable, that requirement is subject to certain exceptions. Among those exceptions includes the need to render emergency assistance. Additionally, the Court raised and dismissed Mr. Case’s arguments that the Court should understand Brigham City as requiring police officers as requiring probable cause to enter a home in emergency situations. However, the Court declined to put a new probable cause spin onto the emergency-aid standard:

“Probable cause is peculiarly related to criminal investigations, and that body of law would fit awkwardly, if at all, in the non-criminal, non-investigatory setting at issue here,” said the Court. It reasoned that rather Brigham City asked simply whether an officer had an objectively reasonable basis for believing that entry was direly needed to prevent or deal with serious harm. “Courts should assess the reasonableness of an emergency-aid entry on its own terms, rather than through the lens generally used to consider investigative activity,” said the Court.

Finally, the Court reasoned that the officers here had an objectively reasonable basis for believing that their entry was needed to prevent Case from ending his life:

“The information the officers obtained from Case’s ex-girlfriend, combined with their observations at the scene, suggested that Case may already have shot himself or would do so absent intervention. The officers’ decision to enter his home to prevent that result was reasonable.” ~U.S. Supreme Court

Accordingly, the Court affirms the judgment of the Montana Supreme Court.

My opinion? Essentially, this opinion rejects the defendant’s attempt to narrow the Court’s decision in Brigham City. Nevertheless, it’s nice to see the Court unanimously agree, even if the subject matter is not terribly complicated.

Similar to Montana, Washington State has its own Community Caretaking Exception (CCE) to the Warrant Requirement. Under State v. Harris, Washington’s CCE allows police to conduct warrantless searches or seizures when performing non-criminal, health, and safety functions, provided it is not a pretext for criminal investigation. This exception requires that officers have a reasonable, objective belief that assistance is needed, balancing privacy against public interest.

Please contact my office if you, a friend or family member are charged with a crime involving Search & Seizure. Hiring an effective and competent defense attorney is the first and best step toward justice.