Docket 24-624
Case v. Montana
DecidedJan 14, 2026
9-0unanimous decision
Source: CourtListener.
Court rules police may enter a home without a warrant to provide emergency aid using an "objectively reasonable" standard
What it does
The Court unanimously reaffirmed that police officers may enter a home without a warrant if they have an "objectively reasonable basis for believing" that someone inside is seriously injured or faces imminent serious injury. The Court rejected the argument that the higher "probable cause" standard — normally required in criminal investigations — must also be met for emergency-aid entries. The Court also rejected Montana's lower "reasonable suspicion" standard, holding that the Brigham City standard stands on its own, with no additional requirements layered on top of it.
Who benefits
Police officers responding to emergency situations who enter a home without a warrant to render aid, as long as their belief that someone inside needs help is objectively reasonable. People inside homes who face a genuine emergency may also benefit, as officers are not required to meet a higher legal bar before intervening.
Who is affected
Homeowners and residents whose homes are entered by police without a warrant during a reported emergency, who cannot challenge that entry by arguing officers needed to meet the higher probable-cause standard used in criminal investigations.
Practical impact
Police officers responding to reported emergencies — such as a possible suicide, a medical crisis, or signs of serious injury — may enter a home without a warrant as long as the totality of the circumstances gives them an objectively reasonable basis to believe someone inside needs immediate help. Courts reviewing such entries must apply the Brigham City standard directly, without importing probable-cause rules from criminal law or using a lower reasonable-suspicion framework. Once inside, officers' authority is limited to what is reasonably necessary to address the emergency.
Majority reasoning
The majority held that the Fourth Amendment's warrant requirement has a well-established exception for emergency aid, first recognized in Brigham City v. Stuart (2006), which allows officers to enter a home without a warrant when they have "an objectively reasonable basis for believing" that an occupant is seriously injured or faces imminent serious injury. The Court reasoned that the "probable cause" standard — which the petitioner urged the Court to adopt — is rooted in and derives its meaning from the criminal investigatory context, and would fit awkwardly in a non-criminal, non-investigatory emergency situation. The Court also rejected Montana's lower standard, which used language echoing "reasonable suspicion" — the standard for brief street stops — finding that Brigham City set its own distinct standard for home entries that is neither probable cause nor reasonable suspicion. Applying that standard to the facts, the Court found the officers' entry was reasonable because they had received a report that Case had threatened suicide, may have fired a gun, and had gone silent, and they observed an empty holster and what appeared to be a suicide note through the windows. The Court emphasized that an emergency-aid entry does not authorize officers to search the home beyond what is reasonably necessary to address the emergency.
Constitutional question
When police enter a home without a warrant to provide emergency aid, must they meet the "probable cause" standard typically required in criminal investigations, or does the lower "objectively reasonable basis for believing" standard from Brigham City v. Stuart apply?
Precedent changed
Extends and reaffirms Brigham City v. Stuart, 547 U.S. 398 (2006), clarifying that its "objectively reasonable basis" standard applies without modification — neither elevated to probable cause nor lowered to reasonable suspicion. Also narrows the Montana Supreme Court's "community caretaker doctrine" by requiring it to conform to the Brigham City standard.