Case v. Montana

Background

William Case, a homeowner, called his ex-girlfriend and said he would kill himself; she heard a clicking sound and later called 9‑1‑1. Montana police found an empty holster, a notepad they took for a suicide note, and beer cans through a window, and Case did not answer when officers knocked. About forty minutes later officers entered to render aid. Case hid in a closet and appeared holding an object like a gun; an officer shot and injured him, and a handgun was found nearby. Case was charged, sought to suppress evidence from the entry, and the Montana Supreme Court upheld the entry under a state “caretaker” rule that used a lower, “specific and articulable facts” suspicion test.

Reasoning

The Court asked whether officers need probable cause to enter a home to provide emergency aid or whether Brigham City’s test—whether there is an “objectively reasonable basis for believing” someone is seriously injured or imminently threatened—controls. The Court held that probable cause is a criminal-investigation concept and need not apply; Brigham City’s objective-reasonableness standard governs. Applying that standard, the Court concluded the officers reasonably believed Case might have shot himself or was about to, so the entry was lawful. Justice Kagan wrote for a unanimous Court and affirmed the Montana judgment, though not all of that court’s reasoning.

Real world impact

The ruling clarifies that police nationwide may enter without a warrant when facts would make a reasonable officer believe serious danger is present. Such entries must be limited to addressing the emergency and do not permit broader searches. The decision resolves conflicting lower-court rules and will shape how officers respond to suicide or other urgent threats.

Dissents or concurrances

Two concurrences stressed different points: Justice Sotomayor warned entries can escalate mental‑health crises and urged de‑escalation and specialist responses; Justice Gorsuch tied the rule to common‑law permissions for private citizens to enter to prevent harm and highlighted limits on officers’ powers.