Case v. Montana, Docket No. 24-624

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When it comes to the Fourth Amendment, the hard part is drawing the line between privacy at home and a real emergency where someone might be hurt. In Case v. Montana, the Supreme Court took up that line again, and the Justices were unanimous in their agreement.

The Court said police can enter a home without a warrant to give emergency help when they have an “objectively reasonable basis” to believe someone inside is seriously injured, or about to be. The Justices rejected two other options: they said the standard is not as low as “reasonable suspicion,” but it also doesn’t require “probable cause,” either. Instead, the Court stuck with the rule it laid out before in a case called Brigham City v. Stuart.

In this case, officers were told William Case was threatening suicide and might have already shot himself. The Court said that was enough for the officers to reasonably believe there was an emergency, so the entry without a warrant was allowed. The Court affirmed the Montana Supreme Court’s decision.

When Police Enter Your Home Without a Warrant: The Supreme Court's Latest Guidance

William Trevor Case asked the U.S. Supreme Court to decide whether Montana police violated his constitutional rights when they entered his home without a warrant. The police had received a 9-1-1 call reporting that Case was threatening to kill himself and may have already shot himself. When officers entered the home, a confrontation occurred that resulted in an officer shooting Case. Police then found a handgun inside. Case was later charged and convicted of assaulting a police officer, but he argued that all evidence from the warrantless entry should be thrown out because the entry was unconstitutional.

The Montana Supreme Court had approved the police entry under what the state calls a "community caretaker doctrine." Under Montana's rule, police need "objective, specific and concrete facts" that lead an officer to "suspect" someone inside needs help. One judge disagreed, arguing that this standard was too weak for entering someone's home and that police should need stronger evidence—what lawyers call "probable cause"—before breaking down your door. The Supreme Court agreed to hear the case because courts across the country have been split on this question: how much evidence do police need before they can enter a home without a warrant to provide emergency aid?

The Court's Decision

Justice Kagan wrote the opinion for a unanimous Court. All nine justices agreed on the outcome. The Court held that the rule from an earlier case called Brigham City v. Stuart applies: police officers may enter a home without a warrant when they have "an objectively reasonable basis for believing" that someone inside is seriously injured or is about to be seriously injured.

Case had argued that the Court should require "probable cause"—a higher standard of evidence—before police can enter. The Court disagreed. Probable cause, the justices explained, is a concept that grew out of criminal investigations. It's designed to answer questions like "Is there probably evidence of a crime here?" or "Did this person probably commit a crime?" That framework doesn't fit well when police are responding to an emergency where someone might be hurt or dying. In those situations, officers aren't investigating a crime—they're trying to save a life. The Court said it would be awkward and inappropriate to force that criminal-investigation standard onto emergency situations.

Instead, the Brigham City rule asks a more direct question: Was it objectively reasonable for the officers to enter, given what they knew about the potential for serious harm?

Applying that standard to Case's situation, the Court found the entry was reasonable. Case's ex-girlfriend had called 9-1-1 and reported that Case had made explicit threats to kill himself, that she heard sounds consistent with a gun being cocked and possibly fired, and then silence. When officers arrived at the scene, they saw additional warning signs: an empty gun holster, what appeared to be a suicide note, and Case didn't respond when they called out. These facts, taken together, gave officers an objectively reasonable belief that Case had shot himself or was about to do so without immediate intervention. The Court therefore ruled in favor of the police and upheld Case's conviction.

The Court also criticized Montana's "community caretaker" label and its use of language that sounded too much like the lower "reasonable suspicion" standard used for brief street stops, not home entries.

Additional Perspectives from the Justices

Justice Sotomayor's Concerns: Justice Sotomayor agreed with the outcome but wrote separately to raise an important caution. She emphasized that when police respond to mental health crises, their entry can sometimes make things worse rather than better—especially when guns are involved. She stressed that courts should carefully consider the specific risks of each crisis situation when deciding whether police entry was reasonable. She also noted that not only does the decision to enter need to be reasonable, but also how police enter and what they do once inside must be reasonable too. These issues weren't argued in Case's appeal, so the Court didn't address them. Still, Justice Sotomayor agreed that the facts here—particularly the possibility that Case had already shot himself—supported the officers' decision to enter, even though some evidence might have suggested Case was trying to provoke police into shooting him.

Justice Gorsuch's Historical View: Justice Gorsuch also agreed with the outcome but wanted to explain the deeper roots of the emergency-aid exception. He argued that this exception isn't just about what judges today think is "reasonable." Instead, it comes from old common-law rules—legal principles that go back centuries—that allowed people to enter another person's property to prevent serious harm. This was called the "necessity privilege." Justice Gorsuch believes grounding the rule in this historical tradition is important because those old common-law rules came with built-in limits: you could only enter to the extent reasonably necessary to address the emergency.

The Legal Question at the Heart of This Case

The Fourth Amendment to the Constitution protects Americans from "unreasonable" searches and seizures. Courts have long said that entering someone's home without a warrant is "presumptively unreasonable"—meaning it's generally not allowed. But the Supreme Court recognizes certain exceptions to this rule, and the emergency-aid exception is one of them.

The tricky question in this case was: what standard should trigger this exception? How much information do police need before they can enter your home without a warrant to provide emergency help?

Montana's rule used language that sounded a lot like "reasonable suspicion"—the standard police need for brief street stops and pat-downs. The Supreme Court said this was misleading. Reasonable suspicion is a relatively low bar designed for quick, less intrusive encounters on the street, not for entering the sanctity of someone's home.

But the Court also refused to require "probable cause," which is a higher standard. Probable cause is the amount of evidence police typically need to get a search warrant or make an arrest. But as the Court explained, probable cause developed specifically for criminal investigations. It's about determining the likelihood that evidence of a crime exists or that someone committed a crime. That framework doesn't translate well to emergency situations where police are making split-second decisions about whether someone is injured or in immediate danger.

So the Court created—or more accurately, reaffirmed—a middle path: a distinct reasonableness test specifically for emergencies. Police can enter when, looking at all the circumstances, they have an objectively reasonable basis to believe immediate aid is needed. And importantly, what police do once inside must be limited to what the emergency requires. They can't use an emergency as an excuse to search your whole house for evidence of crimes.

This isn't about making it easy for police to enter homes. The Fourth Amendment still strongly protects your home. But when someone's life is genuinely at risk, the Constitution allows officers to act—as long as their belief in that risk is objectively reasonable based on the facts they knew at the time.