Facts
In SCOTUS Brigham City v. Stuart, 547 U. S. 398 (2006), this Court held that police officers may enter a home without a warrant if they have an “objectively reasonable basis for believing” that someone inside needs emergency assistance. The question presented is whether that standard means that officers must have “probable cause” for the intrusion, as they typically would when investigating a crime. We hold it does not. The probable-cause requirement is rooted in, and derives its meaning from, the criminal context, and we decline to transplant it to this different one. Brigham City’s reasonableness standard means just what it says, with no further gloss. And here it was satisfied because the police had “an objectively reasonable basis for believing” that a homeowner intended to take his own life and, indeed, may already have shot himself.
This case began with an alarming phone call from William Case to his ex-girlfriend J. H., both residents of a small town in Montana. Case told J. H. on the call that he was going to kill himself. Because Case sounded erratic, J. H. assumed he had been drinking. She tried to talk Case out of committing suicide, but “couldn’t reel him back”: With each passing moment, Case became more methodical about what he was going to do. Case said that he was going to get a note—presumably meaning a suicide note, for J. H. or others to find. And then J. H. heard a “clicking” sound, like the cocking of a gun. J. H. told Case she was going to call the police, but that seemed only to antagonize him: Case replied he would shoot them all too. Finally, J. H. heard “a pop” followed by nothing—just dead air. She yelled Case’s name a few times, but got no response, leading her to think he had pulled the trigger. So she called 9–1–1 to report the incident and drove as fast as she could to Case’s home.
Three police officers, dispatched to do a welfare check on a suicidal male, met J. H. outside the house. They decided the situation was very serious, based both on what J. H. told them about the call and on what they already knew about Case. The officers were aware that Case had a history of alcohol abuse and mental-health issues; that he had previously threatened suicide at the school where he worked; and that he had once seemed to attempt “suicide-by-cop,” by confronting the police in a way that was likely to provoke a lethal response. So the three officers requested that the chief of police come to the scene. While waiting for him, they circled the house looking for signs of injury or danger. They knocked on the doors and yelled into an open window, but got no response. Shining their flashlights inside, they could make out empty beer cans, an empty handgun holster, and a notepad with writing on it, which they took to be the suicide note Case had mentioned to J. H. At that point, however, they saw no sign of Case.
Once the chief came, the officers conferred and decided to enter the house to render emergency aid. In the best-case scenario, they hoped to “talk Case down” and prevent any injury. But given J. H.’s account, the officers considered as well another possibility—that Case had already shot himself and might be in there bleeding. At the same time, they worried that if Case remained unharmed, their entry could spark a confrontation. So they equipped themselves with long-barrel guns and a ballistic shield before going in.
The officers entered the house through the front door, about 40 minutes after they first arrived. They announced themselves loudly, and continued to call out as they walked through the home. Case did not answer; he was hiding in the closet of a bedroom upstairs. When one of the officers entered that room, Case threw open the closet curtain and appeared from behind it, holding “a black object” which looked like a gun. Fearing that he was about to be shot, the officer fired his own rifle. The bullet hit Case in the abdomen, and another officer rushed to administer first aid. An ambulance was called to take Case to the nearest hospital (where he recovered). Meanwhile, one of the officers found a handgun in a laundry basket next to the place where Case had stood.
The county attorney charged Case with assaulting a police officer. Case moved to suppress all evidence obtained as a result of the home entry, arguing that the police had violated the Fourth Amendment by coming into his house without a warrant. The trial court denied the motion on the ground that the police officers were responding legitimately to an “emergency.” A Montana jury then found Case guilty of the crime charged. On appeal, a divided Montana Supreme Court upheld the trial court’s ruling that the officers’ entry was lawful.
Analysis
We granted certiorari (SCOTUS agreed to hear case) because courts have differed on whether police officers entering a home to provide emergency aid need “probable cause” to believe that an occupant is in peril. We conclude that standard, borrowed from the criminal context, is inapt. We instead hold just what we have held before: that the officers may enter if, but only if, they have an “objectively reasonable basis for believing” that an occupant faces serious danger.
The warrant requirement is subject to certain exceptions. And among those is one pertinent here, involving the need to provide an occupant with emergency aid.
This Court first approved a warrantless home entry to render emergency assistance in Brigham City. There, police officers responding to a noise complaint observed through a kitchen window a physical altercation between an adolescent and several adults. As they watched, the teenager punched one of the adults in the face, sending him to the sink spitting blood. The officers immediately entered the home through a nearby screen door and, announcing their presence, caused the fight to cease. We unanimously approved the warrantless entry as reasonable under the circumstances. And we explained what made it so: The officers had “an objectively reasonable basis for believing that an occupant was seriously injured or imminently threatened with such injury.
Three years later, in Michigan v. Fisher, we reiterated what we had said in Brigham City about the “emergency aid exception.” See 558 U. S. 45 (2009). The police in Fisher, also responding to a neighbor’s report, found a scene redolent of violence and danger. Three windows were broken, with the glass strewn on the ground outside; blood was smeared on one of the doors, as well as on the smashed-in hood of a pickup truck in the driveway; and, visible through a window, a man inside the house was screaming and throwing things at an unseen target. We held that the officers’ entry in those circumstances was “reasonable under the Fourth Amendment,” just as it had been in Brigham City. Using the same standard articulated there, we concluded that the officers had “an objectively reasonable basis for believing” that an occupant of the home needed immediate aid.
Finally, in Caniglia, we reaffirmed Brigham City even as we rejected a broader “community caretaking justification for warrantless home entries. The police had gone to Edward Caniglia’s home after his wife reported that he was suicidal. Caniglia spoke with the officers on his front porch and agreed to go to a hospital for psychiatric testing. Then, once he had left, the officers went inside and took away two handguns he owned. The lower courts approved the entry on the ground that the officers were performing “community caretaking functions.” But we declined to recognize such an “open-ended license” for law enforcement officers to enter private homes. Citing Brigham City, we readily acknowledged that officers may enter a home to “render emergency assistance to an injured occupant or to protect an occupant from imminent injury.” But such emergency conditions were indeed necessary and, given the facts, the officers had never tried to defend their entry on that basis.
We decline Case’s invitation to put a new probable-cause spin onto Brigham City. The probable-cause standard, this Court has often stated, is peculiarly related to criminal investigations. So Brigham City adopted a different approach. Rather than strain to relate probable-cause decisions to emergency-aid situations, we asked simply whether an officer had “an objectively reasonable basis for believing” that his entry was direly needed to prevent or deal with serious harm. And in that vein, we note that an emergency aid entry provides no basis to search the premises beyond what is reasonably needed to deal with the emergency while maintaining the officers’ safety. But we assess the reasonableness of that limited entry on its own terms, rather than through the lens generally used to consider investigative activity.
Doing so here yields a ready conclusion: The officers had, as Brigham City requires, an “objectively reasonable basis for believing” that their intervention was needed to prevent serious harm. As earlier described, the officers knew firsthand that Case suffered from mental-health and alcohol-abuse problems, and that he had previously talked about committing suicide. When they reached Case’s house, they learned about J. H. and Case’s just-concluded phone call—that Case, in an apparently inebriated state, threatened to kill himself, spoke of preparing a suicide note, and quite possibly cocked or even shot a gun before the line went dead. The concerns that call raised were heightened by what the officers could see through the window —empty beer cans, an empty holster, and a note-pad—as well as by Case’s failure to respond to their urgent knocking. If Case had already shot himself, he could have been severely injured and in need of immediate medical care. And if he had not, the risk of suicide remained acute, given all the facts then known to the officers. It was thus objectively reasonable for the police to believe that Case needed emergency aid.
Case concludes that if the officers had only left well enough alone, nothing would have happened. But Case much oversimplifies a complex situation. The objective reasonableness of an officer’s conduct under Brigham City, as in other Fourth Amendment contexts, is evaluated by looking at the “totality of the circumstances. One of those circumstances was no doubt that Case could provoke a confrontation. As noted earlier, that was partly why the officers called the police chief to the scene and why they carefully considered protective measures—leading to some delay in their entry. But there is no basis for thinking that the officers would have gone into Case’s home just so he could instigate a gunfight. The circumstances making their entry reasonable, as just stated, were those suggesting that Case may already have shot himself or would do so absent intervention. The statements Case made to J. H. plus the visual evidence corroborating them indicated that Case wanted to end his life. The decision of the officers to enter his home to prevent that resul—even at some significant risk to themselves—was (at the least) reasonable. The Fourth Amendment did not require them, as Case now argues, to leave him to his fate.
We repeat today what we have held before: An officer may enter a home without a warrant if he has an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury. The officers’ entry satisfied that test. Accordingly, we affirm the judgment of the Montana Supreme Court.
It is so ordered.