Save a Life, Skip the Warrant: SCOTUS Backs Emergency Entry

Title & Citation

Case v. Montana, 607 U.S. ___ (2026) (U.S. Supreme Court, Jan. 14, 2026).

TL;DR

Police can enter a home without a warrant to render emergency aid when they have an objectively reasonable basis to believe someone inside is seriously injured or imminently threatened with serious injury—and the Court refused to “upgrade” that standard into probable cause just because the entry is into a home. Here, the officers reasonably believed Case had shot himself or was about to, based on a 911 caller’s report plus on-scene observations.

Why it matters: This is a clean, officer-friendly clarification: the emergency-aid/home-entry standard is objective reasonableness, not “PC of an emergency.” But it also reinforces a limiter: entry is justified to address the emergency—not as a backdoor for broader searching.

Limits: The Court stresses the entry must remain tethered to the emergency (and officer safety), and Justice Sotomayor highlights the special escalation risks in mental-health calls—sometimes entry may increase danger and be unreasonable depending on the mix of facts.

Facts

• Case’s ex-girlfriend called 911 after a disturbing phone call: Case said he was going to kill himself, mentioned getting a “note,” she heard a sound like a gun being cocked, then a “pop,” then silence.

• Officers arrived for a welfare check. They knocked/yelled, got no response, and saw items through a window including an empty handgun holster and a notepad that looked like a suicide note.

• Officers entered about 40 minutes after arrival, announcing themselves. Case was hiding in an upstairs closet. When an officer entered the bedroom, Case emerged holding a dark object that looked like a gun; the officer shot him. A handgun was later found nearby.

• Case was charged with assault on a police officer and moved to suppress evidence, arguing the warrantless entry violated the Fourth Amendment. The motion was denied; conviction affirmed by Montana’s high court; SCOTUS granted review.

Issues

1. For warrantless home entry to render emergency aid, must officers have probable cause to believe someone inside needs aid—or is Brigham City’s “objectively reasonable basis” standard the test?

2. On these facts, did officers have an objectively reasonable basis to enter to prevent death/serious injury?

Court’s Decision

Holding: No probable cause requirement. The governing test is Brigham City: officers may enter without a warrant when they have an objectively reasonable basis to believe an occupant is seriously injured or imminently threatened with such injury. The entry here was reasonable, so the conviction stands.

Reasoning

1. Home entries are presumptively unreasonable—but emergency aid is a recognized exception. The Court reaffirms that warrantless home entries are generally unreasonable, but “emergency aid” is a long-recognized Fourth Amendment exception. Brigham City and Michigan v. Fisher supply the operative rule.

   
   

2. Don’t import “probable cause” into a non-criminal, non-investigatory emergency. The Court refuses to relabel emergency aid as a “probable cause” inquiry. Probable cause doctrine is historically and functionally tied to criminal investigation and evidence-seeking; it doesn’t map cleanly onto rapid emergency risk assessment. The Court keeps the standard as stated: an objectively reasonable basis to believe aid is needed.

   
   

3. Montana’s caretaker framing risked diluting the standard toward “reasonable suspicion.” The Montana Supreme Court’s “community caretaker” language and “specific and articulable facts to suspect” formulation sounded like Terry-style reasonable suspicion—too tied to street-stop logic. SCOTUS says Brigham City already gives the correct home-entry emergency test, and it should be applied “without further gloss.”

   
   

4. Totality of the circumstances supported entry here. The 911 information (suicide threat, “note,” possible gunshot, line went dead) plus the scene observations (empty holster, notepad, no response) made it objectively reasonable to think Case had already shot himself or was about to. Officers weren’t required to “leave him to his fate.”

   
   

5. Sotomayor concurrence: mental-health calls are uniquely volatile—entry can escalate. Justice Sotomayor agrees on the outcome but emphasizes that with mental-health crises, officer presence and entry can sometimes increase risk (including “suicide-by-cop” dynamics). She underscores careful, case-specific assessment and that the manner of entry must also be reasonable (though that wasn’t litigated here).

   
   

6. Gorsuch concurrence: common-law necessity helps justify the doctrine. Justice Gorsuch frames emergency aid as consistent with common-law necessity principles: entry is allowed when it reasonably appears necessary to prevent serious harm—bounded by what’s reasonably needed to address the emergency.

Street Takeaways

• Emergency aid home entry = “objectively reasonable basis,” not probable cause. If the facts would make a reasonable officer believe someone inside is seriously hurt or about to be, that’s the standard.

• Build your “objective basis” from multiple sources: caller info + corroborating observations + lack of response. Document each fact.

• Stay tethered to the emergency. Entry is to locate/render aid and manage immediate safety—not to search generally.

• Mental-health calls can escalate. Consider de-escalation options and specialized resources when feasible; courts may scrutinize whether entry reduced or increased danger given what was known at the time.

• Delay can be reasonable when it’s about safety planning. Here, officers waiting for the chief and equipping protective gear didn’t undercut the emergency rationale; it supported a careful approach.

• Report-writing tip: write it like a timeline. What you learned, what you saw, what you tried (knock/announce), why you believed delay could be fatal, and what scope you intended once inside.

  
  

Disclaimer

This post is for training and informational purposes only and does not constitute legal advice. Officers should follow their agency policies and consult local legal counsel/prosecutors for guidance on specific situations.