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Case v. Montana
Opinion: https://www.supremecourt.gov/opinions/25pdf/607us1r06_19m1.pdf
Case background
Montana police officers responded to the home of petitioner William Case
after his ex-girlfriend called 9-1-1 to report that he was threatening
suicide and may have shot himself. The officers knocked on the doors and
yelled into an open window but got no response; they could see an empty
handgun holster and something that looked like a suicide note inside, and
they ultimately decided to enter the home to render emergency aid. When one
officer approached a bedroom closet in which Case was hiding, Case threw open
the closet curtain while holding an object that looked like a gun, and,
fearing that he was about to be shot, the officer shot and injured Case.
Officers later found a handgun next to where Case had stood. Case was charged
with assaulting a police officer and moved to suppress all evidence obtained
from the home entry, arguing that the police violated the Fourth Amendment by
entering without a warrant. The trial court denied the motion, a jury found
Case guilty, and a divided Montana Supreme Court upheld the officers’ entry
as lawful under Montana’s caretaker doctrine, rejecting the contention that
an officer must have probable cause to believe that an occupant needs
emergency aid.
Questions Presented
(1) Whether law enforcement may enter a home without a search warrant based on less than probable cause that an emergency is occurring, or whether the emergency-aid exception requires probable cause.
Holding
Brigham City’s objective-reasonableness standard for warrantless home entries
to render emergency aid applies without further gloss, and it was satisfied
in this case. The probable-cause requirement is rooted in, and derives its
meaning from, the criminal-investigation context, and the Court declined to
transplant it onto the emergency-aid exception. Officers may enter a home
without a warrant when they have an objectively reasonable basis for believing
that an occupant is seriously injured or imminently threatened with such
injury. The information the officers obtained from Case’s ex-girlfriend,
combined with their observations at the scene, gave them just such a basis to
believe that Case may already have shot himself or would do so absent
intervention, so the Court affirmed the judgment — though not all the
reasoning — of the Montana Supreme Court.
The Court
Justice Kagan delivered the opinion for a unanimous Court. Justice Sotomayor
and Justice Gorsuch each filed concurring opinions.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in
Case v. Montana, written by Justice Kagan.
AI disclosure: The voice in this episode is AI-generated, using a machine
learning model styled to loosely resemble the authoring justice. Tone,
inflection, pacing, and emphasis are artifacts of the model and should not be
attributed to Justice Kagan. The text being read is the Court’s published
majority opinion, lightly adapted to improve readability for the spoken format.
View all episodes
By So OrderedOpinion: https://www.supremecourt.gov/opinions/25pdf/607us1r06_19m1.pdf
Case background
Montana police officers responded to the home of petitioner William Case
after his ex-girlfriend called 9-1-1 to report that he was threatening
suicide and may have shot himself. The officers knocked on the doors and
yelled into an open window but got no response; they could see an empty
handgun holster and something that looked like a suicide note inside, and
they ultimately decided to enter the home to render emergency aid. When one
officer approached a bedroom closet in which Case was hiding, Case threw open
the closet curtain while holding an object that looked like a gun, and,
fearing that he was about to be shot, the officer shot and injured Case.
Officers later found a handgun next to where Case had stood. Case was charged
with assaulting a police officer and moved to suppress all evidence obtained
from the home entry, arguing that the police violated the Fourth Amendment by
entering without a warrant. The trial court denied the motion, a jury found
Case guilty, and a divided Montana Supreme Court upheld the officers’ entry
as lawful under Montana’s caretaker doctrine, rejecting the contention that
an officer must have probable cause to believe that an occupant needs
emergency aid.
Questions Presented
(1) Whether law enforcement may enter a home without a search warrant based on less than probable cause that an emergency is occurring, or whether the emergency-aid exception requires probable cause.
Holding
Brigham City’s objective-reasonableness standard for warrantless home entries
to render emergency aid applies without further gloss, and it was satisfied
in this case. The probable-cause requirement is rooted in, and derives its
meaning from, the criminal-investigation context, and the Court declined to
transplant it onto the emergency-aid exception. Officers may enter a home
without a warrant when they have an objectively reasonable basis for believing
that an occupant is seriously injured or imminently threatened with such
injury. The information the officers obtained from Case’s ex-girlfriend,
combined with their observations at the scene, gave them just such a basis to
believe that Case may already have shot himself or would do so absent
intervention, so the Court affirmed the judgment — though not all the
reasoning — of the Montana Supreme Court.
The Court
Justice Kagan delivered the opinion for a unanimous Court. Justice Sotomayor
and Justice Gorsuch each filed concurring opinions.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in
Case v. Montana, written by Justice Kagan.
AI disclosure: The voice in this episode is AI-generated, using a machine
learning model styled to loosely resemble the authoring justice. Tone,
inflection, pacing, and emphasis are artifacts of the model and should not be
attributed to Justice Kagan. The text being read is the Court’s published
majority opinion, lightly adapted to improve readability for the spoken format.