The U.S. Supreme Court unanimously ruled this week that Anaconda police officers did not violate the Fourth Amendment when they entered a man’s home without a warrant during a suspected mental health emergency, delivering a major legal victory aligned with arguments advanced by Montana Attorney General Austin Knudsen and sharply rejecting a dissent by Montana Supreme Court Justice Laurie McKinnon.
The decision upheld the outcome reached by the Montana Supreme Court, which had affirmed the conviction of William Trevor Case for assaulting a peace officer. However, while agreeing with the result, the nation’s high court made clear that it disagreed with aspects of the Montana court’s reasoning and took the unusual step of directly criticizing McKinnon’s dissent as extreme and wrong on the law.
The case stemmed from a September 2021 incident in Anaconda, when police conducted a welfare check after Case told his former girlfriend that he intended to kill himself and would shoot any officers who came to his home. The girlfriend contacted 9-1-1, prompting three officers to respond.
When officers arrived, Case did not answer the door or respond to shouts through an open window. Officers observed empty beer cans, an empty handgun holster, and what they believed to be a suicide note inside the home. They were also aware of prior incidents in which Case had threatened suicide and, in one instance, appeared to be attempting to provoke police into shooting him.
After roughly 40 minutes, officers entered the home without a warrant, believing Case may have already harmed himself or was in immediate danger. Inside, Case emerged from a closet holding what officers believed was a firearm. One officer shot Case in the abdomen. A handgun was later found nearby. Case survived and was ultimately convicted by a jury of assaulting a peace officer.
Case sought to suppress the evidence obtained after the warrantless entry, arguing that police were required to have probable cause before entering his home, even in an emergency. Montana courts rejected that argument, and Case appealed to the U.S. Supreme Court.
In an 11-page opinion authored by Justice Elena Kagan, the Court adopted the legal standard advanced by Attorney General Knudsen, holding that officers may enter a home without a warrant when they have an objectively reasonable basis to believe that an occupant is seriously injured or imminently threatened with such injury.
The Court emphasized that while the home lies at the core of Fourth Amendment protections, longstanding precedent recognizes an emergency-aid exception to the warrant requirement. The justices declined Case’s invitation to impose a probable-cause requirement in emergency, non-criminal situations, explaining that such a standard applies in criminal investigations and fits awkwardly, if at all, in circumstances involving efforts to prevent imminent harm.
Although the Court agreed with the Montana Supreme Court’s ultimate conclusion, it explicitly rejected the reasoning in Justice McKinnon’s dissent, which argued that first responders must have probable cause before entering a home even in an emergency. The justices described that view as an incorrect interpretation of Fourth Amendment law and inconsistent with established precedent, including the Court’s 2006 decision in Brigham City v. Stuart.
Applying the proper legal test, the Court concluded that Anaconda officers had an objectively reasonable basis to believe their intervention was necessary to prevent serious harm. The opinion also dismissed the argument that police created the danger by entering the home, noting that the circumstances suggested Case may have already injured himself or would do so without intervention.
Justice Sonia Sotomayor wrote a concurring opinion highlighting the heightened risks faced by individuals experiencing mental health crises during police encounters and urging consideration of de-escalation strategies where feasible. She nevertheless agreed that, under the facts of this case, the officers’ actions were reasonable. Justice Neil Gorsuch also concurred, grounding the emergency-aid exception in longstanding common-law principles allowing entry to prevent serious harm.
The ruling represents a significant affirmation of the emergency-aid doctrine and a clear endorsement of the position taken by Attorney General Knudsen before the Court. It also sends a pointed message to lower courts, including the Montana Supreme Court, about the limits of Fourth Amendment protections in life-threatening emergencies and the proper legal standard governing warrantless entries.