SCOTUS Reaffirms Fourth Amendment Standard for Police Responding to Household Emergencies

In Case v. Montana, 607 U.S. ____ (2026), the U.S. Supreme Court confirmed thatthe Fourth Amendment allows police officers to enter a home without a warrant if they have an “objectively reasonable basis for believing” that someone inside needs emergency assistance. In so ruling, the Court rejected the argument that police officers need “probable cause” to believe someone is in urgent need of help.

Facts of the Case

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. Fearing that he was about to be shot, the officer shot and injured Case. An ambulance was called to take Case to the hospital, and officers found a handgun next to where Case had stood. Case was charged with assaulting a police officer. Case 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, and a jury found Case guilty. 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.

Supreme Court’s Decision

The Supreme Court reversed. “The question presented is whether that standard means

that officers must have ‘probable cause’ for the intrusion, as they typically would when investigating a crime. “We hold it does not,” Justice Elena Kegan wrote on behalf of the unanimous Court. “The probable-cause requirement is rooted in, and derives its meaning from, the criminal context, and we decline to transplant it to this different one.”

In reaching its decision, the Court acknowledged that“[w]hen the intrusion is into that most private place, ‘reasonableness’ usually means having a warrant.” However, it also noted that the warrant requirement is subject to certain exceptions, including the need to render emergency assistance. As relevant here, in Brigham City v. Stuart, 547 U.S. 398 (2006), the Court held that the Fourth Amendment allows police officers to enter a home without a warrant if they have an “objectively reasonable basis for believing” that someone inside needs emergency assistance. According to the Supreme Court, “Brigham City’s reasonableness standard means just what it says, with no further gloss.”

The Supreme Court further found that Montana Supreme Court’s opinion strayed from that rule, noting that the emergency-aid test incorporated in Montana’s caretaker doctrine evokes the Fourth Amendment standard of “reasonable suspicion” that applies to relatively non-invasive street stops. However, Brigham City formulated its own standard for dealing with household emergencies

In reaffirming the standard, the Supreme Court declined to “put a new probable-cause spin onto Brigham City.” In support, it emphasized that the probable-cause standard applies exclusively in criminal settings, and “would fit awkwardly, if at all, in the non-criminal, non-investigatory setting at issue.”
The Supreme Court went on to hold that the Brigham test was satisfied. “If Case had already shot himself, he could have been severely injured and in need of immediate medical care,” Justice Kagan explained. “And if he had not, the risk of suicide remained acute, given all the facts then known to the officers. It was thus objectively reasonable for the police to believe that Case needed emergency aid.”