The decision clarifies the scope of the ‘emergency aid’ exception to the Fourth Amendment’s warrant requirement, rejecting a higher standard Case sought and finding fault with the lower standard the Montana Supreme Court had applied — while still ruling against Case on the facts of his specific encounter.
WASHINGTON — The Supreme Court ruled unanimously Wednesday that Montana police acted lawfully when they entered a man’s home without a warrant in response to a reported suicide threat, finding the officers’ conduct “objectively reasonable” under existing constitutional standards.
The case involved William Case, who was shot and wounded in 2021 after officers entered his home without a warrant. Officers responded to a call from Case’s former girlfriend, who feared he might have killed himself. They knocked on the door and, after receiving no response, entered the home. An officer fired after Case threw open a closet curtain while holding an object that looked like a gun, according to court documents. A handgun was later found in a nearby laundry basket.
Case was charged with assaulting an officer. He argued the evidence against him should be tossed out because officers lacked a warrant.
The competing legal standards
The Montana Supreme Court rejected Case’s suppression argument, holding that officers needed only to reasonably suspect someone required emergency help. Case appealed to the justices and asked them to require a higher probable cause standard, comparable to what officers must meet in a criminal investigation.
The Supreme Court rejected both positions. The justices found the Montana Supreme Court’s standard too low but concluded that the officers’ specific actions were nevertheless “objectively reasonable” under a standard established in a prior Supreme Court ruling. Justice Elena Kagan wrote the opinion for the court.
Kagan noted in the opinion that entering a home to respond to an emergency does not give officers license to search beyond what is necessary to provide aid and ensure officer safety.
Background on the emergency-entry doctrine
The Fourth Amendment generally requires police to obtain a warrant before entering a home. Courts have recognized a narrow exception when officers have an objectively reasonable basis to believe someone inside needs emergency assistance. Wednesday’s ruling addresses how that standard is applied, and draws a line between the emergency-aid context and the higher threshold required for criminal investigations.