The Caretaking Exception to the Fourth Amendment: Unpacking Caniglia v. Strom and Its Constitutional Limits

• In Event: Frameworks for Interpreting and Reforming the Law

Abstract

In 2021, the United States Supreme Court held in a unanimous decision that police officers’ community caretaking duties does not justify warrantless entry into the home. This narrow exception effectively allowed police officers to perform certain duties unrelated to criminal investigations, such as check on an individual’s well-being or responding to a medical emergency, without the need for home-owner consent or a warrant. This opinion bore three major interpretations. First, community caretaking exception applies strictly to vehicles, but not homes. Second, the Court abolished the community caretaking exception. And third, the exception was absorbed under emergency aid exception. This study aims to investigate this phenomena more closely by systematically reviewing state and federal criminal cases using a content analysis research design. The implications of the study are discussed.

Authors

• James Alexander Purdon, East Texas A&M University

• Christopher Totten, Kennesaw State University