WASHINGTON, D.C. — Edward Caniglia and his wife had a nasty fight on Aug. 20, 2015, so bitter that his wife decided to spend the night at a hotel.
When Caniglia didn’t answer the phone the next day, his wife, Kim, called the Cranston police, worrying that he might be suicidal. He had retrieved an unloaded gun during their argument the day before and said, “Why don’t you just shoot me and get me out of my misery.”
Officers questioned Caniglia and sent him to Kent Hospital for an evaluation, a step Caniglia said he agreed to only after police assured him they wouldn’t take his guns. Officers nonetheless seized his two guns and ammunition. Caniglia was released from the hospital the same day.
Caniglia, backed by the Rhode Island affiliate of the American Civil Liberties Union, sued the police after they refused to return his guns without a court order. The guns were returned 3½ months later, only after he filed suit.
“I immediately felt like it was a miscarriage of justice. … If they can come and do this with these firearms, when can they take away my car because I ran a stop sign? It seemed arbitrary,” Caniglia, 70, said.
On Monday, the U.S. Supreme Court ruled unanimously that Cranston had violated Caniglia’s Fourth Amendment rights by entering his home and seizing the guns and having him taken to the hospital without a warrant.
“I feel terrific. I was right,” Caniglia said.
“None of this has been anti-police but anti- their reactions that day. It was a little bit out of hand,” Caniglia said. He isn’t seeking damages, he says, but only to be compensated for his legal expenses.
Thomas W. Lyons III and Rhiannon Selina Huffman represented him in U.S. District Court and the 1st U.S. Circuit Court of Appeals. Shay Dvoretzky argued the case before the U.S. Supreme Court.
“They worked so hard for me,” Caniglia said, in an interview conducted in Lyons’ office. “They’re my heroes.”
The case — which touched on the sanctity of one’s home, gun rights and police officers’ duty to make snap decisions in myriad situations — stemmed from an argument between the Caniglias that snowballed to the point that he retrieved an unloaded gun, Caniglia concedes.
Officers at the scene questioned Caniglia. He says he told them he would never commit suicide and stepped away during the conversation to take his high-blood pressure medication. Still, the officers had him taken to the hospital, where doctors sent him home with his wife after a few hours.
“They really didn’t know why I was there,” he said of the staff. The couple remain married, though he reports not talking to his wife for a few weeks after the incident.
“Why they had come into my house and taken everything didn’t make any sense,” said Caniglia, who doesn’t consider himself a gun-rights advocate or a backer of the NRA.
U.S. District Court Chief Judge John J. McConnell Jr. in 2019 ruled in favor of the Cranston police, concluding that officers were acting in keeping with their duty to protect the public under the so-called community caretaking exception when they sent Caniglia to get evaluated and seized his guns without a warrant. The 1st U.S. Circuit Court of Appeals upheld that decision a year later.
“Police officers must sometimes make on-the-spot judgments in harrowing and swiftly evolving circumstances. Such considerations argue persuasively in favor of affording the police some reasonable leeway in the performance of their community caretaking responsibilities,” Senior Circuit Judge Bruce Selya wrote for the appeals court.
Caniglia sought a Supreme Court review, challenging the ruling as an unconstitutional expansion of the community-caretaking exception.
The Supreme Court heard virtual arguments in March that contemplated just when police may enter a home without a warrant.
The Supreme Court in 1973 held that police officers did not violate the Fourth Amendment when they searched the trunk of a car without a warrant. Courts nationwide have since been split on whether those protections should be extended into homes, with some expanding the community caretaking exception into homes.
In a ruling written by Justice Clarence Thomas, the high court found that searches of homes and vehicles were constitutionally distinguishable.
“The very core of the Fourth Amendment’s guarantee is the right of a person to retreat into his or her home and ‘there be free from unreasonable governmental intrusion,’” the court wrote. “A recognition of the existence of ‘community caretaking’ tasks, like rendering aid to motorists in disabled vehicles, is not an open-ended license to perform them anywhere.”
In a concurring ruling, Justice Brett Kavanaugh cautioned that courts, police officers and police departments must take care in situations in which a person could be at risk to be sure a warrantless entry is “reasonable under the circumstances.”
Cases involving armed, suicidal people; an elderly person who fails to attend church and can’t reached; and young, unattended children “illustrate the kinds of warrantless entries that are perfectly constitutional under the exigent circumstances doctrine, in my view,” Kavanaugh wrote.
“The takeaway is that the home is entitled to greater constitutional protections than an automobile unless there are existing exceptions, such as an emergency circumstance or consent,” Lyons said. Otherwise officers need to secure a warrant.
Dvoretzky, partner at Skadden, Arps, Slate, Meagher & Flom LLP, put it in this context.
“The First Circuit’s now-discarded standard would have allowed officers to demand entry into people’s homes based on subjective and undefined ‘community-caretaking’ needs. In rejecting that standard, the Supreme Court reaffirmed bedrock Fourth Amendment principles, and held that police do not have ‘an open-ended license to perform’ community caretaking tasks in the home. The Court’s holding is a significant victory for Americans concerned about the sanctity of their homes,” he said in a statement.
The Rhode Island affiliate of the American Civil Liberties Union hailed the ruling as an important victory for privacy rights.
“The Fourth Amendment has always served as an important barrier to police intrusion into the home, and we are very pleased that the Court reaffirmed this fundamental principle,” ACLU of Rhode Island Executive Director Steven Brown said in a statement.
The ruling returns the case to the 1st U.S. Circuit Court of Appeals, which could in turn send it back to the U.S. District Court to address any issues the Supreme Court opinion did not resolve.
Marc DeSisto, who represented Cranston, could not be reached for comment Monday. The communications coordinator for the city also didn’t return a phone call late Monday.
Rhode Island enacted a red-flag law in 2018, after Caniglia brought his case. That law allows for police to remove firearms, by court order, from people who pose a significant danger to themselves or others.