Supreme Court Clarifies Emergency Aid Exception to 4th Amendment Warrant Requirement
Posted in Fourth Amendment on February 10, 2026
U.S. Supreme Court Clarifies Emergency Aid Exception to the Fourth Amendment
In Case v. Montana, the U.S. Supreme Court reaffirmed that police may enter a home without a warrant when they have an objectively reasonable basis to believe an occupant is seriously injured or facing imminent harm. The Court rejected the argument that probable cause is required in emergency aid situations. This exception to the 4th Amendment’s warrant requirement is known as the Emergency Aid Exceptions.
Background of the Case
William Trevor Case threatened suicide during a phone call with his ex-girlfriend and made sounds consistent with cocking or firing a gun. After the call abruptly ended, police were dispatched for a welfare check. When officers arrived, they observed corroborating signs through the home’s windows, including empty beer cans, an empty handgun holster, and a notepad believed to be a suicide note. Case did not respond to repeated attempts to make contact. Concerned that he had already shot himself—or was about to—the officers entered the home without a warrant to render emergency aid.
The encounter escalated when Case emerged holding what appeared to be a firearm, resulting in him being shot by police. He survived and was later charged with assault on a police officer. Case moved to suppress the evidence, arguing the warrantless entry violated the Fourth Amendment.
The U.S. Supreme Court’s Holding
The emergency aid exception allows warrantless entry when officers have an objectively reasonable basis to believe an occupant is seriously injured or imminently threatened with such injury.
Courts should not import criminal probable-cause doctrine into emergency aid cases.
- The Court also cautioned against reliance on the term “community caretaking” in home-entry cases, reiterating its rejection of that doctrine in Caniglia v. Strom. The proper inquiry is emergency aid—not generalized caretaking.
Evidence Suppressed in State College DUI
In a State College DUI case, the police made a warrantless entry into a DUI suspect’s residence and claimed that the emergency aid exception applied. The police claimed that they had reason to believe that the suspect needed may be suffering a medical episode and needed immediate assistance. While the police claimed that immediate entry was required, they actually waited approximately 15 to 20 minutes for a supervisor to arrive on scene before making the entry. After entering, they arrested the suspect, removed him from his home, and charged with him a DUI. The Superior Court later ruled that the warrantless entry was not justified under the emergency aid exeption and thereby suppressed all evidence. For more information about the case, click here.