Brigham City v. Stuart
Citation: 547 U.S. 398 (2006)
Facts
Officers responding to a noise complaint saw, through a window, a fight in which a juvenile was being held and struck by adults, with one adult spitting blood. Officers entered without a warrant.
Issue
May police enter a home without a warrant when they witness what appears to be an ongoing assault causing injury?
Holding
Yes. Officers may enter a home without a warrant when they have an objectively reasonable basis to believe that an occupant is in immediate need of aid or that evidence of an ongoing violent crime is being destroyed.
Rule
Emergency aid exception (community caretaking): Police may enter a home without a warrant when they have an objectively reasonable basis to believe that: (1) someone inside is in immediate need of emergency assistance, OR (2) there is an ongoing violent crime causing injury. The officer’s subjective motivation is irrelevant — the test is objective.
Significance
- Clarifies and expands the emergency aid / community caretaking exception to the warrant requirement
- Objective test: what would a reasonable officer believe given the observed facts?
- Courts apply this exception most often to domestic violence situations and medical emergencies
- Caniglia v. Strom (2021) subsequently limited community caretaking: the doctrine does not apply to homes the same way it applies to vehicles; community caretaking does not create a free-floating exception for any wellness check