Supreme Court rules against police in warrantless search of RI man's home
WASHINGTON, D.C. - Edward Caniglia and his wife had a heated argument on August 20, 2015, so bitter that his wife decided to spend the night in a hotel.
When Caniglia did not answer the phone the next day, his wife Kim called the police in Cranston, Rhode Island, fearful he might commit suicide. The day before, during their argument, he had retrieved an unloaded gun and said, "Why don't you just shoot me and get me out of my misery?"
Edward Caniglia reacts to the Supreme Court decision.
The officers questioned Caniglia and sent him to Kent Hospital for an examination. A move that Caniglia only agreed to after the police assured him that they would not take his guns. Officers nevertheless seized his two weapons and ammunition. Caniglia was discharged from the hospital the same day.
Caniglia, supported by the Rhode Island subsidiary of the American Civil Liberties Union, sued police after they refused to return his guns without a court order. The guns were returned 3½ months later, only after he filed a lawsuit.
"I immediately felt it was a miscarriage of justice ... If you can come and do this with these guns, when can you take my car because I had a stop sign? It seemed arbitrary," said Caniglia, 70 years old old.
On Monday, the US Supreme Court ruled unanimously that Cranston had violated Caniglia's Fourth Amendment rights by entering his home, confiscating the guns and having him hospitalized without a warrant.
"I feel great. I was right," said Caniglia.
"None of that was against the police that day, it was against their reactions. It was a bit out of control," said Caniglia. He is not looking for compensation, only to be compensated for his legal costs.
Thomas W. Lyons III and Rhiannon Selina Huffman represented him in the US District Court and the 1st US Court of Appeals. Shay Dvoretzky argued the case in the US Supreme Court.
Edward Caniglia with lawyers Rhiannon Selina Huffman and Thomas W. Lyons III, whom he describes as his "heroes".
"You worked so hard for me," Caniglia said in an interview in Lyon's office. "They are my heroes."
More: Cranston police seized a man's guns in 2015. What the US Supreme Court heard about it in 2021:
The case, which touched on the sanctity of one's own home, gun rights and the duty of police officers to make quick decisions in innumerable situations, arose out of an argument between the Caniglias that was so covered in snow that he retrieved an unloaded gun, Caniglia admits.
Police at the scene interviewed Caniglia. He said he told them he would never commit suicide and during the conversation he stepped down to take his high blood pressure medication. Even so, the officers had him taken to the hospital, where the doctors sent him home with his wife a few hours later.
"They really didn't know why I was there," he said of the staff. The couple remain married, despite reports that they haven't spoken to his wife for a few weeks after the incident.
"Why they came to my house and took it all made no sense," said Caniglia, who does not consider himself a gun rights advocate or a supporter of the NRA.
U.S. District Court Chief Justice John J. McConnell Jr. ruled in 2019 in favor of the Cranston Police Department, concluding that the officers were in line with their duty to protect the public under what is known as the Community Care Exemption acted when they sent Caniglia for assessment and seized his guns without a warrant. The 1st US Court of Appeals upheld that decision a year later.
“Police officers sometimes have to pass judgments on the ground in harrowing and rapidly evolving circumstances. Such considerations are a convincing argument in favor of giving the police reasonable leeway in the performance of their duties as community administrators, ”wrote Senior Circuit Judge Bruce Selya for the Court of Appeal.
Caniglia requested a review by the Supreme Court and challenged the ruling as an unconstitutional extension of the community care exemption.
The Supreme Court heard virtual arguments in March considering when police could enter a home without an arrest warrant.
The Supreme Court ruled in 1973 that police officers did not break the fourth amendment when they searched the trunk of a car without an arrest warrant. Courts across the country have since divided over whether to extend this protection to homes, with some extending the community care exemption to homes.
In a ruling by Judge Clarence Thomas, the Supreme Court found that house and vehicle searches were constitutionally distinguishable.
Judge Clarence Thomas wrote the decision.
"The essence of the Fourth Amendment guarantee is a person's right to retreat to their home and" be free from inappropriate government interference, "" the court wrote. "Recognizing the existence of community caretaking tasks, such as providing assistance to drivers in disabled vehicles, is not a perpetual license to do it anywhere."
In a unanimous decision, Judge Brett Kavanaugh warned that courts, law enforcement officers and law enforcement agencies must be careful in situations where a person could be at risk to ensure that legal entry is "appropriate in the circumstances".
Cases of armed suicides; an elderly person who does not attend church and cannot be reached; and young unsupervised children "illustrate the types of unlawful entries which I believe are wholly constitutional under the doctrine of urgent circumstances," wrote Kavanaugh.
"To take away, the house is entitled to better constitutional protection than an automobile, unless there are exceptions such as an emergency or consent," said Lyons. Otherwise, the officers must obtain an arrest warrant.
The American Civil Liberties Union's subsidiary in Rhode Island hailed the ruling as a major victory for privacy rights.
"The fourth amendment has always been a major barrier to police entry and we are delighted that the Court has reaffirmed that rationale," said Steven Brown, executive director of the Rhode Island ACLU, in a statement .
The verdict routes the case back to the U.S. First Court of Appeals, which in turn could send it back to the U.S. District Court to resolve any issues that the Supreme Court opinion failed to resolve.
Marc DeSisto, who represented Cranston, could not be reached for comment on Monday. The city's communications coordinator also didn't return a call late Monday.
Rhode Island passed red flag law in 2018 after Caniglia brought his case. This law allows the police, upon court order, to remove firearms from persons who pose a significant threat to themselves or others.
This article originally appeared in The Providence Journal: RI Arms Seizure, held by the US Supreme Court.
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