Caniglia v. Strom, No. 19-1764 (1st Cir. 2020)Annotate this Case
The First Circuit held that the special measure of constitutional protection to which police officers, in the motor vehicle context, performing community care taking functions are entitled extends to police officers performing community caretaking functions on private premises, including homes.
Plaintiff's person and firearms were allegedly seized after Defendants, police officers, entered his home. Plaintiff brought several claims against Defendants, including claims brought under 42 U.S.C. 1983 and under state law. The district court granted summary judgment in favor of Defendants on Plaintiff's federal and state-law claims, concluding that the officers' conduct at Plaintiff's residence constituted a reasonable exercise of their caretaking responsibilities and thus did not violate Plaintiff's Fourth Amendment rights. The First Circuit affirmed, holding that Defendants' actions did not exceed the proper province of their community caretaking responsibilities.