William Trevor Case v. Montana (24-624)
- Term
- OT 2025
- Argued
- 2025-10-15
- Decided
- 2026-01-14
- Vote
- 9-0 for Montana
- Opinion
- Justice Kagan
- Majority
- Roberts, Thomas, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
The case in brief
Facts
William Case's ex-girlfriend called 911 to report that he was threatening suicide and might have shot himself. Montana police went to his home, got no answer, and saw an empty handgun holster and what looked like a suicide note, so they went inside without a warrant to give emergency help. Inside, Case stepped out of a closet holding what looked like a gun, and an officer shot and wounded him. Case was charged with assaulting an officer and asked the court to throw out the evidence from the entry, but the trial court refused and a jury convicted him. A divided Montana Supreme Court upheld the entry and rejected Case's argument that police needed probable cause to believe someone inside needed emergency aid.
Question
When police enter a home without a warrant to help someone in an emergency, must they have probable cause (the fairly strong level of proof normally used in criminal investigations) to believe someone inside needs help, or is a lower standard enough?
Conclusion
Montana won in a unanimous 9-0 decision written by Justice Kagan. The Court held that officers need only an objectively reasonable basis for believing someone inside needs emergency help, not probable cause, because probable cause is tied to criminal investigations and fits poorly in emergencies. Given what the officers knew, they reasonably believed entry was needed to stop Case from taking his life, so the Court affirmed the Montana judgment while disagreeing with some of that court's reasoning. Justices Sotomayor and Gorsuch wrote concurring opinions; Justice Sotomayor warned that police presence can sometimes make a mental-health crisis more dangerous rather than less.
Opinion of the Court
Authored by Justice Kagan (7,313 words total).
Volume 607 U. S. Part 1 Pages 107–127
THE SUPREME COURT January 14, 2026
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NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors.
certiorari to the supreme court of montana No. 24–624. Argued October 15, 2025—Decided January 14, 2026 In Brigham City v. Stuart, 547 U. S. 398, 400, the Court held that the Fourth Amendment allows police offcers to enter a home without a warrant if they have an “objectively reasonable basis for believing” that someone inside needs emergency assistance. In this case, Montana police offcers responded to the home of petitioner William Case after his ex-girlfriend called 9–1–1 to report that he was threatening suicide and may have shot himself. The offcers knocked on the doors and yelled into an open window, but got no response. They could see an empty handgun holster and something that looked like a suicide note inside, and they ultimately decided to enter the home to render emergency aid. When one offcer approached a bedroom closet in which Case was hiding, Case threw open the closet curtain while holding an object that looked like a gun. Fearing that he was about to be shot, the offcer shot and injured Case. An ambulance was called to take Case to the hospital, and offcers found a handgun next to where Case had stood. Case was charged with assaulting a police offcer. Case moved to suppress all evidence obtained from the home entry, arguing that the police violated the Fourth Amendment by entering without a warrant. The trial court denied the motion, and a jury found Case guilty. A divided Montana Supreme Court upheld the offcers' entry as lawful under Montana's caretaker doctrine, rejecting the contention that an offcer must have probable cause to believe that an occupant needs emergency aid.
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Held: Brigham City's objective reasonableness standard for warrantless home entries to render emergency aid applies without further gloss and was satisfed in this case. Pp. 113–119. (a) “[S]earches and seizures inside a home without a warrant are presumptively unreasonable” under the Fourth Amendment. Brigham City, 547 U. S., at 403. But the “warrant requirement is subject to certain exceptions,” Lange v. California, 594 U. S. 295, 301, including the need to render emergency assistance. The Court frst approved a warrantless home entry to render emergency assistance in Brigham City, holding that offcers may enter when they have “an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury.” 547 U. S., at 400.
The Montana Supreme Court's opinion below strayed from that rule. Most important, the emergency-aid test incorporated in Montana's caretaker doctrine evokes the Fourth Amendment standard of “reasonable suspicion” that applies to relatively non-invasive street stops. But Brigham City adopted a different standard for home entries. Case now urges the Court to understand Brigham City as sounding in probable cause, but the Court declines to put a new probable-cause spin onto the emergency-aid standard. Probable cause is “peculiarly related to criminal investigations,” Treasury Employees v. Von Raab, 489 U. S. 656, 667, and that body of law would ft awkwardly, if at all, in the non-criminal, non-investigatory setting at issue here. Rather than strain to relate probable-cause decisions to emergency-aid situations, Brigham City asked simply whether an offcer had “an objectively reasonable basis for believing” that entry was direly needed to prevent or deal with serious harm. 547 U. S., at 400. Courts should assess the reasonableness of an emergency-aid entry on its own terms, rather than through the lens generally used to consider investigative activity. Pp. 113–117. (b) The offcers here had an “objectively reasonable basis for believing” that their entry was needed to prevent Case from ending his life. The information the offcers obtained from Case's ex-girlfriend, combined with their observations at the scene, suggested that Case may already have shot himself or would do so absent intervention. The offcers' decision to enter his home to prevent that result was reasonable. Accordingly, the Court affrms the judgment (even though not all the reasoning) of the Montana Supreme Court. Pp. 117–119. 417 Mont. 354, 553 P. 3d 985, affrmed.
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