In a unanimous decision with significant implications for Fourth Amendment law, the Supreme Court of the United States has ruled that police officers may enter a person’s home without a warrant when they reasonably believe emergency aid is needed, even in the absence of probable cause. The case, Case v. Montana, arose from a welfare check involving a reported suicide threat and ultimately tested the constitutional limits of warrantless home entry.
The case began when William Case’s former girlfriend contacted 9-1-1 after Case told her he intended to kill himself and would shoot any police officers who came to his home. Officers in Anaconda, Montana responded to the call for a welfare check. When Case failed to answer the door or respond to shouted commands, officers observed empty beer cans, an empty handgun holster, and what appeared to be a suicide note inside the residence. They were also aware of Case’s prior history of suicidal behavior and threats involving law enforcement.
After approximately forty minutes on scene, officers entered the home without a warrant. Case was found hiding in an upstairs closet holding a dark object officers believed to be a firearm. An officer shot Case in the abdomen, and a handgun was later recovered nearby. Case was charged and convicted of assaulting a police officer, but he moved to suppress all evidence obtained after the warrantless entry, arguing that the Fourth Amendment required probable cause and a warrant before police crossed the threshold of his home.
Writing for a unanimous Court, Justice Elena Kagan rejected that argument. The Court reaffirmed that while the home occupies a central place in Fourth Amendment protections, longstanding precedent recognizes exceptions to the warrant requirement. One such exception is the “emergency-aid” doctrine, which allows officers to enter a residence without a warrant when they have an objectively reasonable basis to believe that someone inside is seriously injured or imminently threatened with such injury.
The Court relied heavily on its prior decision in Brigham City v. Stuart, which upheld warrantless entry where officers observed an ongoing violent altercation through a window. In that case, the Court held that the proper inquiry is not probable cause in the criminal sense, but whether the officers’ belief that immediate aid was necessary was objectively reasonable under the circumstances.
Justice Kagan emphasized that importing a probable-cause standard into non-criminal, emergency situations would be doctrinally awkward and practically unworkable. The officers in Case, she wrote, were responding to credible information suggesting a risk of suicide and potential gun violence, and the facts known to them at the time justified immediate intervention. The Fourth Amendment, she cautioned, does not demand that officers stand by while a person may be dying inside a locked home.
At the same time, the Court made clear that the emergency-aid exception is not unlimited. Officers may not use a welfare check as a pretext to conduct a broader search unrelated to the emergency, and any intrusion must be strictly tailored to addressing the perceived threat while maintaining officer safety.
Why This Decision Matters
For defendants and defense counsel, Case v. Montana reinforces that challenges to warrantless home entries during welfare checks will turn on the specific facts known to officers at the time, not on hindsight or generalized distrust of police motives. For law enforcement, the ruling confirms authority to act decisively in genuine emergencies, while reaffirming that such authority is tightly circumscribed.
If you or a loved one is facing criminal charges arising from a welfare check, mental-health intervention, or warrantless home entry, the constitutional analysis is highly fact-specific and often litigable. Experienced defense counsel can evaluate whether police conduct truly fit within the narrow emergency-aid exception or crossed constitutional lines.
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