The Court would determine if the 'community caretaking exception' to the Fourth Amendment would apply to a person’s residence as well as to their car.
The community caretaking exception allows the police to search without a warrant to seize evidence while performing community caretaker function. This could also include caretaking activities performed by officers that are "totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute." However, the application of this exception is being debated.
U.S. Court of Appeals for the 1st Circuit in 2020 upheld the police officer's actions under the community caretaking exception to the Fourth Amendment in the case Caniglia v. Strom. In 2015, Edward Caniglia and his wife Kim Caniglia had a heated discussion at their home in Cranston, Rhode Island. During which Mr. Caniglia retrieved an unloaded handgun in a "dramatic gesture," which alarmed his wife. Mrs. Caniglia spent the night in a hotel and the next morning called her husband to check on him. Failing to get in touch with him, she called the Cranston Police Department, requesting them to check on her husband and escort her back home. She even told the officers about the gun she hid before leaving and how she was worried about her husband taking his own life. Owing to the circumstances, the officers sent Mr. Caniglia to the hospital to check on his mental health and searched his home without obtaining a warrant. The police seized two guns from the couple's home. Mr. Caniglia sued the department for violating his Fourth Amendment right to privacy and his Second Amendment right to keep handguns in the home for self-protection. After losing the case in the lower court, Mr. Caniglia appealed to the U.S. Supreme Court, which the court agreed to hear on March 24, 2021.
The Supreme Court will now decide on extending the community caretaking exception to warrantless searches of the home, or would it account to police having bypassed the Fourth Amendment's restrictions.