New 2021 SCOTUS in the Classroom Case
February 22, 2021
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We are excited to announce our new SCOTUS in the Classroom case: Caniglia v. Strom. This case deals with the controversial “community caretaker” role of the police and whether it establishes an exception to the warrant requirement found in the Fourth Amendment.
Due to the coronavirus pandemic, the oral arguments in this case will take place via telephone on March 24, 2021. They will be made available for the media to broadcast live. Teachers and students are encouraged to hold moot courts (or mini-moot courts) of the case the same week that the Supreme Court hears arguments, giving students the opportunity to follow discussion and analysis in the news and, of course, tune in live. The moot court teaching strategy may be conducted virtually or in-person.
Street Law will post case materials as they become available on the SCOTUS in the Classroom program page. You can also find instructions and handouts for conducting a moot court on the program page.
Facts
Edward Caniglia had no criminal history, no record of violence, no gun violations, and had never been known to self harm. In August 2015 he had a heated argument with his wife, Kim, in their home in Cranston, Rhode Island. As the argument worsened, he went to their bedroom, and returned with his unloaded handgun. He put the gun on the table and said to his wife, “Why don’t you just shoot me and get me out of my misery?” Mrs. Caniglia decided to go to a motel for the night.
The next day, Mrs. Caniglia called home. When her husband did not answer, she became worried and called the police to ask that they make a “well call” to check on him and escort her home. Mrs. Caniglia told the officers about the argument, explained the reasons she was concerned for her husband’s safety, and told them he could be suicidal.
Officers believed there was a possibility Mr. Caniglia might self-harm, so an officer told Mr. Caniglia he was taking him to a hospital for a psychiatric evaluation. Mr. Caniglia was examined by a physician, a nurse, and a social worker and was discharged.
While Mr. Caniglia was at the hospital, officers entered the home to seize the handguns because they feared he might harm himself or others. Earlier, Mr. Caniglia told them, “You’re not confiscating anything.” The officers lied to Mrs. Caniglia telling her that husband consented. Based on that, Mrs. Caniglia took the officers to the bedroom and garage where the guns were located. The officers seized the guns.
The Caniglias asked for the guns back on several occasions, but the police refused. Mr. Caniglia alleged that the city violated his rights under the Second Amendment (right to bear arms), Fourth Amendment (unreasonable search and seizure), and the 14th Amendment’s Due Process and Equal Protection Clauses. After he filed the lawsuit, his guns were returned. The District Court found for Mr. Caniglia on the 14th Amendment Due Process Clause claim because the city had no process for recovering his guns after they had been seized. It found against Mr. Caniglia on all his other claims. It stated that the community caretaking services the police provide could be required in homes as well as vehicles and that this exception to the Fourth Amendment justified the warrantless entry and seizures of the guns.
This case asks the following important question: Does the “community caretaking” exception to the Fourth Amendment’s warrant requirement extend to the home?
SCOTUS in the Classroom is made possible by the support of the Supreme Court Historical Society.
Image: Two police officers face off against a figure in their home.
