The U.S. Supreme Court ruled unanimously on Jan. 14 that police do not need to obtain a warrant to enter a home when they reasonably believe a person inside needs emergency assistance.
The ruling upholds what lawyers call the community caretaker doctrine. The doctrine holds that police don’t always operate as law enforcement officers investigating wrongdoing, but sometimes function as community caretakers to prevent harm in emergencies.
Justice Elena Kagan wrote the court’s opinion in Case v. Montana, saying a 20-year-old precedent applies.
Kagan said in the new opinion that in Brigham City v. Stuart (2006), the court found that police officers are allowed to enter a home without a warrant “if they have an ‘objectively reasonable basis for believing’ that someone inside needs emergency assistance.”
“The question presented is whether that standard means that officers must have ‘probable cause’ for the intrusion, as they typically would when investigating a crime. We hold it does not,” the justice said.
Probable cause allows police to arrest someone, carry out a search, or seize property. There is probable cause to enter a home without a warrant when there is a threat to public safety or a belief that a crime is being committed or evidence is in danger of being destroyed.
Kagan said the reasonableness standard articulated in Brigham City was satisfied here because the police had “‘an objectively reasonable basis for believing’ that a homeowner intended to take his own life and, indeed, may already have shot himself.”
The case goes back to Sept. 27, 2021, when William Trevor Case was shot by local police after they entered his Montana home.
Law enforcement arrived at the home after Case’s ex-girlfriend told them he was threatening to kill himself. The police officers did not seek a warrant because, as one officer said, “It wasn’t a criminal thing. [They] were going in to assist him,” according to a summary in the Montana Supreme Court ruling of Aug. 6, 2024.
Case didn’t respond to knocking on the door, so police looked through a window and saw an empty handgun holster. They were reluctant to enter the home because the ex-girlfriend told them he had threatened to harm not just himself, but also police officers, and because they knew about Case’s mental health issues, according to the summary.
Eventually, police gained entry through an unlocked front door and moved to the upstairs bedroom, where they found Case with an object an officer thought was a gun. Body camera footage later confirmed that Case was pointing a handgun at the officer, according to Montana’s brief filed with the U.S. Supreme Court.
The officer said he shot Case in the abdomen because he believed Case was about to fire on him. Case was charged with felony-level assault on a peace officer, according to the summary.
Assault doesn’t necessarily involve a person suffering physical injury. Assault can be defined as an act that causes another person to reasonably fear that harmful or offensive touching is going to take place, even if no physical contact actually follows.
Case moved to suppress the evidence of the alleged assault obtained from the warrantless entry, arguing it was inadmissible because the entry was a violation of the Fourth Amendment, which protects individuals from unreasonable government searches and seizures, according to the petition that Case filed with the U.S. Supreme Court.
At trial, the motion to exclude the evidence based on unlawful police entry was denied, and Case was convicted.
On appeal, the Montana Supreme Court affirmed 4–3 the denial of the suppression motion, finding that the community caretaker doctrine applied.
The state high court upheld the conviction and found that police officers had “objective, specific, and articulable facts” showing that Case was in need of help because he was “suicidal and potentially intoxicated.”
The state court held that the doctrine applies “when a peace officer acts on a duty to promptly investigate situations ‘in which a citizen may be in peril or need some type of assistance from an officer,’” the petition stated.
The state court found that police do not need to have probable cause for an emergency to justify making a warrantless entry.
Justice Neil Gorsuch filed a concurring opinion.
The exception to the warrant requirement in Brigham City “permits entry only to the extent reasonably necessary to address the apparent emergency and does not authorize officers to search a home more broadly,” he said.
The exception comes out of judge-made law, which has “generally permitted a private citizen to enter another’s house and property in order to avert serious physical harm.” Under such law, “officers generally enjoy the same legal privileges as private citizens,” Gorsuch said.
Justice Sonia Sotomayor also filed a concurring opinion, saying that police need to be especially cautious in situations like that which they faced at Case’s home.
Sotomayor said studies demonstrate that individuals with serious mental health conditions are seven times more likely than members of the general population to be killed during police interactions.
Given the risks involved, it may sometimes be more reasonable for police “to try different means of de-escalation before entering the home of a person experiencing a mental-health crisis,” she said.
Sam Dorman contributed to this report.
This article by Matthew Vadum appeared Jan. 15, 2026, in The Epoch Times.
Photo: Supreme Court Justice Elena Kagan