U.S. Supreme Court News | Case v. Montana

The Fourth Amendment provides that the

“right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.” [1]

Warrantless searches inside a home are presumptively unreasonable. [2]

          Seems simple, right? Well, not quite. The Fourth Amendment warrant requirement has certain exceptions allowing warrantless entry such as fighting a fire, preventing the imminent destruction of evidence, or being in hot pursuit of a fleeing suspect. [3] Another exception is the need to assist someone who is seriously injured or threatened with injury. [4]

          Recently, in Case v. Montana, [5] the U.S. Supreme Court clarified what was required for the emergency aid exception. In the underlying case, William Case called his ex-girlfriend threatening to kill himself and there was a “pop” followed by silence. The ex-girlfriend called the police and three officers were dispatched to do a welfare check on a suicidal male. Looking inside, they saw empty beer cans, an empty handgun holster, and a notepad with writing that looked like a suicide note. The officers entered Case’s house. They hoped to get to him before he injured or killed himself, but they also knew he could have already shot himself and might be somewhere in the house bleeding to death. Case was found in a closet upstairs. He threw open the closet door holding a black object. Fearing that he would be shot, one of the officers shot Case. Case was thereafter charged with assaulting a police officer and moved to suppress all the evidence on the basis of an improper warrantless entry.

          The issue eventually reached the U.S. Supreme Court. The Court held, as they had before, that the probable cause standard was an inappropriate standard to require for police entering a home under the emergency aid exception. Instead, the court held that

“An officer may enter a home without a warrant if he has ‘an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury.’”

          Fourth Amendment issues are often complicated and require navigating complex facts and provisions of law. If you or someone you love is in need of postconviction relief or an appeal, contact Peter Armstrong, Attorney at Law, for a free consultation today.

Citations:

1.    U.S. Const. amend. IV. (https://constitution.congress.gov/constitution/amendment-4/)

2.    Payton v. New York, 445 U.S. 573, 586 (1980). (https://supreme.justia.com/cases/federal/us/445/573/)

3.    Brigham City v. Stuart, 547 U.S. 398, 403 (2006). (https://supreme.justia.com/cases/federal/us/547/398/)

4.    Id.

5.    Case v. Montana, 2026 U.S. LEXIS 432 (2026). (https://www.supremecourt.gov/opinions/25pdf/24-624_b07d.pdf)

6.    Id. at 15 (quoting Brigham City, 547 U.S. at 400).