Supreme Court ruling could allow warrantless home search, gun seizure
A court case stemming from a years-old domestic dispute in Rhode Island could have serious implications for the already evaporating landscape of privacy and citizen's rights in the United States.
Last Wednesday, the United States Supreme Court heard oral arguments in Caniglia v. Strom, a case revolving around the legality of warrantless police search and seizure.
During a 2015 argument between Edward Caniglia, 68, and his wife, Kim Caniglia, Edward placed an unloaded gun on the kitchen table and told his wife, “Why don’t you just shoot me and get me out of my misery,” according to court filings. She later hid his gun and left the home to spend the night in a hotel. The following day, after several failed attempts to reach her husband by phone, she called the Cranston, Rhode Island police department to request a wellness check. The police found Edward Caniglia on his back porch and despite telling officers that he was not suicidal or in need of mental health services, Caniglia was sent to the hospital for evaluation. Court documents show that Caniglia only agreed to hospitalization under the condition that police not seize his firearms. The officers reportedly agreed.
After Caniglia left the scene, officers did seize his guns. Legal filings indicate that cops lied to Kim Caniglia, telling her that her husband had agreed to the seizure of his firearms. Under the false impression that she was carrying out her husband's wishes, she then led police to the two handguns in the home.
After being evaluated by a nurse and social worker, Caniglia was discharged from the hospital and returned home. His firearms and ammunition, however, were not returned to him until after he filed a civil rights lawsuit against the involved officers.
Caniglia's original suit alleged that the seizure violated his civil rights under 42 U.S. Code § 1985 as well as his Fourth Amendment rights. The officers argued that their actions fell within the protections provided under the Fourth Amendment's "community caretaker" exception. Both a district court and the 1st Circuit U.S. Court of Appeals sided with the officers, agreeing that the warrantless search and seizure were legally protected. According to the 1st Circuit, the "community caretaking" exception, "is designed to give police elbow room to take appropriate action." The court ultimately concluded that the officers who confiscated Caniglia's firearms “did not exceed the proper province of their community caretaking responsibilities.”
Now, the case is before the Supreme Court and justices have already heard arguments from attorneys representing Caniglia, the police, and the U.S. Justice Department. The court seeks to clarify "whether the "community caretaking” exception to the Fourth Amendment’s warrant requirement extends to the home."
President Biden's Justice Department has joined the district and 1st Circuit Appeals courts in siding with the Rhode Island police. Last month, the U.S. Department of Justice filed an amicus brief arguing in favor of qualified immunity for the officers implicated in the case even if the court hold that their actions did not meet the standard of the "community caretaking" exception.
The issue of qualified immunity has been a major point of controversy in light of the continuing trend of police brutality, particularly toward communities of color. Social justice organizations nationwide have also helped bring discussions about the fairness of qualified immunity into the mainstream. The Montgomery, Alabama-based Equal Justice Initiative (EJI), a non-profit focused on ending mass incarceration via criminal justice reform, offers a detailed explanation of qualified immunity and its legal history.
The EJI describes the qualified immunity doctrine this way:
The Supreme Court created qualified immunity in the 1960s to limit civilians’ right to sue police officers and other government officials for excessive force and other constitutional violations. The doctrine provides that a police officer can’t even be put on trial for misconduct unless:
1) the evidence shows that the conduct was unlawful; and
2) the officers should have known they were violating “clearly established” law, because a prior court case had already deemed similar police actions to be illegal. “The doctrine of qualified immunity often acts as an ‘absolute shield’ against accountability for police officers, even when there’s no dispute that they used excessive force,”
During last Wednesday's hearing, questions from the justices ranged from the practical to hypothetical, with Chief Justice John Roberts asking whether police would be justified, under community caretaking standards, in entering the home of an elderly woman who failed to show up for her weekly meetings. Justice Stephen Breyer suggested that officers might need to enter a private residence without a warrant if, for instance, "a rat’s come out of a house at a time when rats carry serious disease and have to be stopped."
Supreme Court Justices Sonia Sotomayor and Samuel Alito both noted issues with arguments supporting qualified immunity based on the broad and potentially boundless interpretations of "community caretaking."
"I am deeply concerned about the 1st Circuit's claim that there is no requirement that officers must select the least intrusive means of fulfilling community caretaking responsibilities," remarked Sotomayor.
Although the Caniglia case is far from over, a decision in favor of the Cranston police officers could mark a significant expansion in the power of police and a related decrease in accountability for police misconduct.
As the United States struggles to face its past and present failures in the administration of justice and police accountability, there is no doubt that the outcome will be influenced in part by politics, public opinion, and the nation's highest court.