SCOTUS Unanimous: Defining the Limits of the Emergency Aid Exception in Case v. Montana

By Arjan Bir Sodhi for Lex Republica.

In the unanimous decision of Case v. Montana (2026), the Supreme Court of the United States reaffirmed the "emergency aid exception" to the Fourth Amendment’s warrant requirement. Writing for the Court, Justice Kagan held that police may enter a home without a warrant when they possess an "objectively reasonable basis" for believing an occupant needs immediate assistance. The Court specifically rejected the petitioner’s argument that such entries should be governed by the more stringent "probable cause" standard typically reserved for criminal investigations.
The case originated from a 2024 incident in a small Montana town. Petitioner William Case’s ex-girlfriend contacted 9-1-1 after a distressing phone call in which Case stated he was going to kill himself. During the call, she heard a "clicking" sound similar to a gun cocking, followed by a "pop" and then "dead air". Upon arriving at the residence, officers observed through a window an empty handgun holster and a notepad with writing they believed to be a suicide note. Despite knocking and shouting, the officers received no response from Case. After a forty-minute assessment, the officers entered the home to render aid. Inside, Case emerged from a closet holding a black object; an officer, fearing for his life, shot and injured him. A handgun was subsequently recovered near the scene.
Justice Kagan’s opinion clarified that the "probable cause" standard is "peculiarly related to criminal investigations" and fits "awkwardly" in non-investigatory, emergency settings. The Court emphasized that while the home holds a "first among equals" status under the Fourth Amendment, the law does not require officers to "leave [a person] to his fate" when a life is at stake. However, this authority is not absolute; a warrantless emergency entry provides no license to search a home beyond what is reasonably necessary to address the crisis and ensure safety.
Additionally, the High Court took the chance to correct the reasoning of the Supreme Court of Montana, although the judgment was affirmed. It was argued that the reliance by the Supreme Court of Montana on the "community caretaker doctrine" was misguided, as the doctrine was held in the case of Caniglia v. Strom (2021) to only prevent the doctrine from sometimes being an open-ended exception for entering homes. Moreover, the "reasonable suspicion"
In her concurring opinion, Justice Sotomayor called attention to the dangers peculiar to mental health welfare checks. She noted the statistics showing that people with severe mental illness face a disproportionate risk of being physically harmed or killed in interactions with the police. Sotomayor emphasized the importance of officers using de-escalation techniques such as phone call attempts or special crisis response teams whenever possible as an alternative to forced entry. Justice Gorsuch wrote in his concurring opinion that the emergency aid exception is rooted in the common law tradition and has consistently sacrificed property rights in the face of the inherent risk of serious physical injury.

References

Primary Case: Case v. Montana, 607 U.S. ___ (2026).

Statutory & Constitutional Provisions: U.S. Const. amend. IV.

Cited Precedents:

• Brigham City v. Stuart, 547 U.S. 398 (2006).

• Caniglia v. Strom, 593 U.S. 194 (2021).

• Lange v. California, 594 U.S. 295 (2021).

• Michigan v. Fisher, 558 U.S. 45 (2009) (per curiam).

• Terry v. Ohio, 392 U.S. 1 (1968).

State Court Decision: State v. Case, 417 Mont. 354, 553 P.3d 985 (2024).