Case v. Montana · ¶19

The Montana Supreme Court's opinion strayed from the Fourth Amendment rule that trio of decisions sets out. To begin with, the court's use of “community caretaker” doctrine was ill-advised, given that Caniglia contrasted “community caretaking” with “render[ing] emergency assistance” and concluded that the former cannot alone justify a warrantless home entry. Ibid. The Montana court, to be sure, tried to reconcile its approach with Caniglia by depicting its community-caretaker rule as allowing home entries only in emergencies. See 553 P. 3d, at 991. But using terminology that this Court has held misplaced in home-entry cases could serve only to confuse the issue. And yet more fundamental, the emergency-aid test incorporated in Montana's caretaker doctrine is different from the one adopted in Brigham City. As noted above, Montana's test finds a home entry “reasonable” when an officer has…

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