CASE V. MONTANA, 2026 WL 96690 (2026)
The Fourth Amendment places the home at the center of its protections, but it has never made the front door an impenetrable barrier. When officers confront credible information that an occupant may be seriously injured or facing imminent harm, the Constitution permits limited entry without a warrant. In Case v. Montana, the U.S. Supreme Court unanimously reaffirmed that principle and resolved lingering confusion over the legal standard governing emergency-aid entries.
The question before the Court was narrow but important: whether officers must have probable cause to enter a home and render emergency assistance, or whether the longstanding emergency-aid standard articulated in Brigham City v. Stuart (547 U.S. 398 (2006)) governs. The Court held probable cause — “rooted in, and deriving its meaning from, the criminal context” — does not apply. Instead, the correct inquiry remains whether officers had “an objectively reasonable basis for believing” someone inside needed emergency aid.
The case arose from an alarming phone call from William Case to his former girlfriend, J.H., in a small Montana town. During the call, Case told J.H. he was going to kill himself. He sounded erratic, leading her to believe he had been drinking. As the call progressed, J.H. believed Case became more deliberate about what he intended to do. He mentioned he was “going to get a note,” which she understood to be a suicide note.
J.H. then heard a sound she described as similar to the cocking of a firearm. When she told Case she was going to call police, he responded that he would “shoot them all too.” The call ended with a “pop” followed by silence. J.H. repeatedly called Case’s name but received no response, leading her to believe he may have pulled the trigger. She called 911 and drove to his home.
Three officers were dispatched to conduct a welfare check. They met J.H. outside Case’s residence and concluded that, based on her account and their prior knowledge of Case, the situation was “very serious.” Officers were aware Case had a history of alcohol abuse and mental health issues, had previously threatened suicide at his workplace, and had once allegedly attempted “suicide-by-cop.”
Understanding the seriousness of the situation, the officers requested their chief of police to come to the scene. While waiting for the chief to arrive, the officers circled the house, knocked on doors, and called out through an open window — with no response. Shining flashlights through windows, officers observed empty beer cans, an empty handgun holster, and a notepad containing writing they believed might have been a suicide note. They did not see Case.
After conferring with the chief, officers decided to enter the home to “render emergency aid.” Besides the risk that entry could provoke a confrontation, they also considered the possibility that Case might still be alive and in need of immediate medical care. Approximately 40 minutes after their arrival, officers entered through the front door, announcing themselves as they cleared the residence.
They found Case hiding in an upstairs closet. When an officer entered the bedroom, Case abruptly pulled aside the curtain of the closet, holding a dark object that appeared to be a firearm. The officer fired a single round, striking Case in the abdomen. Another officer immediately rendered first aid. Case survived. Officers later found a handgun in a nearby laundry basket.
Case was charged with assault on a peace officer. He moved to suppress evidence obtained from the warrantless entry, arguing the entry violated the Fourth Amendment. The trial court denied the motion, concluding officers were responding to an emergency. A jury convicted Case.
On appeal, the Montana Supreme Court affirmed. In its opinion, the majority analyzed the entry under its “community caretaker doctrine,” holding officers could enter a home when “objective, specific and articulable facts” would lead an experienced officer to suspect a person inside was in peril. The court rejected Case’s argument that probable cause was required.
The U.S. Supreme Court granted certiorari to resolve disagreement among courts regarding the appropriate standard for emergency-aid entries. SCOTUS began its discussion by reviewing Brigham City v. Stuart, where it held officers may enter a home without a warrant if they have “an objectively reasonable basis for believing” an occupant is seriously injured or imminently threatened with such injury. The Court emphasized this standard “means just what it says, with no further gloss.”
The Court rejected Case’s argument that the Brigham City standard should be reinterpreted to require probable cause. Probable cause, the Court explained, develops in the criminal investigatory context and carries doctrinal baggage ill-suited to emergency situations where officers are not seeking evidence but attempting to prevent serious harm.
The Court reaffirmed Michigan v. Fisher (558 U.S. 45 (2009)), where officers entered a home after observing broken windows, blood, and violent behavior, and Caniglia v. Strom (593 U.S. 194 (2021)), which rejected a broad community-caretaking justification for home entry but reaffirmed the emergency-aid exception. The court noted that emergency conditions are not required, but when they exist, Brigham City governs.
The justices criticized Montana’s reliance on community-caretaker terminology and its use of language resembling reasonable suspicion. The emergency-aid exception is neither a Terry stop nor a criminal investigation. It has its own standard: objective reasonableness based on the totality of circumstances.
Applying that standard, the Court found the officers’ entry reasonable. Officers knew of Case’s mental health and substance-abuse history, his prior suicide threats, and his earlier apparent “suicide-by-cop” behavior. They had a firsthand report of an explicit suicide threat, mention of a note, sounds consistent with firearm manipulation or discharge, and an abrupt loss of contact. On scene, officers observed corroborating evidence and received no response to repeated attempts at communication.
The Court acknowledged the risk that entry could provoke a confrontation and noted officers factored that risk into their decision-making, delaying entry and preparing protective measures. But the circumstances also suggested Case may already have shot himself or remained at acute risk of doing so. Under those circumstances, it was objectively reasonable for officers to enter to render aid. The Fourth Amendment, the Court concluded, did not require officers to refrain from acting in the face of such danger.
Officers can rely on three principles established or reinforced by Case v. Montana:
- Emergency-aid entry does not require probable cause. The governing standard remains whether officers have an objectively reasonable basis for believing an occupant faces serious injury or imminent harm.
- In light of Caniglia v. Strom, courts should avoid reliance on “community caretaker” language when analyzing home entries. Emergency aid is the proper framework.
- Measured delay and tactical planning do not negate exigency. Officers are permitted (and expected) to balance competing risks while responding to rapidly evolving situations.
Case v. Montana does not expand police authority. It restates a settled rule and clarifies its application. When officers reasonably believe a life may be at stake, the Constitution permits limited entry into a home for the sole purpose of rendering emergency assistance.
