SCOTUS decides a 4th Amendment case

It's been a while! The decision is Case v. Montana, which held: Brigham City’s objective reasonableness standard for warrantless home entries to render emergency aid applies without further gloss and was satisfied in this case. From SCOTUSblog:

The Supreme Court on Wednesday upheld the conviction of a Montana man who was convicted of assaulting a police officer. In a unanimous decision written by Justice Elena Kagan, the court ruled in Case v. Montana that police officers in Anaconda, Montana, did not violate the Fourth Amendment when they entered William Case’s home without a warrant, rejecting Case’s contention that the police officers needed “probable cause” to go into his house. Under the Supreme Court’s earlier cases, Kagan wrote, it was enough that the police officers reasonably believed that Case – whose former girlfriend had called them to tell them that Case had threatened to commit suicide – needed emergency assistance.

The case began in 2021, when Case told his former girlfriend, identified in court papers as J.H., that he “was going to kill himself” and would also shoot any police officers who came to his house. J.H. called 9-1-1, which sent three police officers to the scene for a “welfare check on a suicidal male.”

Although Case did not answer when police officers knocked on the door or yelled into an open window, the police officers saw empty beer cans, an empty handgun holster, and what they believed to be a suicide note in the house. The police officers were also aware that Case had threatened to commit suicide before; on another occasion, police officers believed that Case was trying to goad them into shooting him.

Roughly 40 minutes after they arrived, the police officers entered the home. Case was hiding in a closet in an upstairs bedroom, where he was holding a black object that officers believed was a gun. One officer shot Case in the abdomen; another officer discovered a handgun in a laundry hamper near Case.

Case asked the trial court to exclude the evidence that law enforcement officials obtained after they entered his house, arguing that police officers should have had a warrant. But the state courts rejected that argument, prompting Case to come to the Supreme Court.

Case contended that if police officers enter a home without a warrant to provide emergency assistance, they must have probable cause “to believe someone is in urgent need of help.” On Wednesday the Supreme Court disagreed. In an 11-page opinion, Kagan acknowledged that the sanctity of the home is at the core of the Fourth Amendment, which protects the people from “unreasonable searches and seizures.” As a general rule, she explained, “[w]hen the intru­sion is into that most private place, ‘reasonableness’ usu­ally means having a warrant.” But there are exceptions to that general rule, she continued, including “the need to provide an occupant with emergency aid.”

Speaking of SCOTUSblog, its founder Tom Goldstein started his trial this week. I think they opened today. More on that soon.