SCOTUS grants review in two cases concerning law enforcement officers’ search-and-seizure authority

On November 20, 2020, the Supreme Court of the United States (SCOTUS) granted review in two cases for a total of two hours of oral argument during its October Term for 2020-2021. The cases have not yet been scheduled for argument. 

Caniglia v. Strom

The case: In 2015, Edward Caniglia and his wife had an argument at their home. During the argument, Caniglia brought out an unloaded gun from their bedroom. Mrs. Caniglia stayed the night at a nearby hotel. In the morning, she called the police to request a wellness check on her husband and an escort to their home, and she stated that she was concerned for her husband’s well-being. At the home, the police spoke with Caniglia. The sergeant determined that Caniglia was imminently dangerous to himself and to others. The police requested that Caniglia go to a nearby hospital for a psychiatric evaluation. Caniglia complied, alleging that he did so based on a promise from police that they would not confiscate his guns. The police record does not include evidence of such a promise. The sergeant entered the home and seized two firearms, two magazines, and ammunition. Later, Caniglia attempted to retrieve his firearms from the police department several times. His requests were denied. Caniglia filed suit in the U.S. District Court for the District of Rhode Island against the police department and the City of Cranston, Rhode Island, alleging violations to the Second and Fourth Amendments to the U.S. Constitution and to Rhode Island state law. The firearms were returned to Caniglia. The district court granted the defendants’ motion for summary judgment. On appeal, the U.S. Court of Appeal for the 1st Circuit affirmed the district court’s ruling.

The issue: Whether the Fourth Amendment’s warrant requirement “community caretaking” exception extends to the home.

United States v. Cooley

The case: In 2016, Crow Tribe of Montana Officer James Saylor detained Joshua Cooley and searched Cooley’s vehicle, which was pulled over in Indian Country on U.S. Route 212. Saylor confiscated several firearms and observed equipment that appeared to contain methamphetamine. Cooley was arrested and indicted in the U.S. District Court for the District of Montana. The district court granted Cooley’s motion to suppress evidence from Saylor’s search. The district court ruled Saylor acted outside of his authority by conducting an “unreasonable search and seizure” under the Indian Civil Rights Act. The U.S. government appealed, but the U.S. Court of Appeals for the 9th Circuit affirmed the lower court’s ruling. The U.S. government then appealed to the U.S. Supreme Court.

The issue: Whether the District of Montana and the 9th Circuit were wrong to suppress evidence on the theory that an Indian tribe police officer was unauthorized to detain and search a non-Indian based on a potential violation of state or federal law while on a public right-of-way in an Indian reservation.

The Supreme Court began hearing cases for the term on October 5, 2020. The court’s yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.

As of November 24, 2020, the court had agreed to hear 45 cases during its 2020-2021 term. Of those, 12 were originally scheduled for the 2019-2020 term but were delayed due to the coronavirus pandemic. The court had issued opinions in two cases this term. The cases were decided without argument.

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