On January 14, 2026, a unanimous United States Supreme Court decided the case of Case v. Montana. The principal issue concerned application of the “emergency aid” exception to the warrant requirement.
The case was decided under Fourth Amendment grounds. The Fourth Amendment provides the minimum protections against unlawful searches and seizures that apply under the federal constitution. States are free to provide their citizens greater protections under their state constitutions. Article I, paragraph seven is the provision of the New Jersey Constitution that is analogous to the Fourth Amendment.
Justice Kagan wrote for the Court in relevant part: In Brigham City v. Stuart, 547 U. S. 398, 400, 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. In this 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. Brigham City’s objective reasonableness standard for warrantless home entries to render emergency aid applies without further gloss and was satisfied in this case.
“Searches and seizures inside a home without a warrant are presumptively unreasonable” under the Fourth Amendment. Brigham City, 547 U. S., at 403. But the “warrant requirement is subject to certain exceptions,” Lange v. California, 594 U. S. 295, 301, including the need to render emergency assistance. The Court first approved a warrantless home entry to render emergency assistance in Brigham City, holding that officers may enter when they have “an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury.” 547 U. S., at 400. The Montana Supreme Court’s opinion below strayed from that rule.
Most important, 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. But Brigham City adopted a different standard for home entries. Case now urges the Court to understand Brigham City as sounding in probable cause, but the Court declines to put a new probable-cause spin onto the emergency-aid standard. Probable cause is “peculiarly related to criminal investigations,” Treasury Employees v. Von Raab, 489 U. S. 656, 667, and that body of law would fit awkwardly, if at all, in the non-criminal, non-investigatory setting at issue here. Rather than strain to relate probable-cause decisions to emergency-aid situations, Brigham City asked simply whether an officer had “an objectively reasonable basis for believing” that entry was direly needed to prevent or deal with serious harm. 547 U. S., at 400. Courts should assess the reasonableness of an emergency-aid entry on its own terms, rather than through the lens generally used to consider investigative activity.
The officers here had an “objectively reasonable basis for believing” that their entry was needed to prevent Case from ending his life. The information the officers obtained from Case’s ex-girlfriend, combined with their observations at the scene, suggested that Case may already have shot himself or would do so absent intervention. The officers’ decision to enter his home to prevent that result was reasonable. Accordingly, the Court affirms the judgment (even though not all the reasoning) of the Montana Supreme Court.
The Montana Supreme Court’s 4-3 split decision appears to have been based on application of the Fourth Amendment or its own analogous state constitutional provision that is no more protective than the Fourth Amendment. Had the Montana Supreme Court adopted the view of its three dissenting justices and couched its decision in terms of application of their state constitution, there would have been no further review. That is because a state Supreme Court is the final arbiter of decisions resting on state grounds. Here, the decision was based on the federal Fourth Amendment. The United States Supreme Court is the final arbiter of the federal Fourth Amendment.
The Montana Supreme Court’s dissent argued that the “emergency aid” exception should require probable cause to believe a person is in imminent danger, rather than just reasonable suspicion. The dissenters believed that a warrantless entry based on “mere reasonable suspicion” would allow the police to unduly undermine the sanctity of the home.
