This post summarizes decisions released by the United States Supreme Court on May 17, 2021. As always, they will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to present.
Caniglia v. Strom, 593 U.S. ___, ___ S. Ct. ___ (May 17, 2021). In this case involving a welfare check that resulted in officers entering petitioner Caniglia’s home without a warrant and seizing his firearms, the court held that its decision in Cady v. Dombrowski, 413 U.S. 433 (1973) upholding as reasonable a “caretaking search” of an impounded vehicle for a firearm did not create a standalone doctrine that justifies warrantless searches and seizures in the home. Following an argument where Caniglia put a gun on a table and told his wife to shoot him, officers accompanied his wife to their shared home to assess his welfare. During that visit, Caniglia agreed to be taken for a mental health evaluation and officers entered his home to confiscate two pistols against his expressly stated wishes. Caniglia later sued, alleging that officers violated his Fourth Amendment rights by the warrantless seizure of him and his pistols. The First Circuit affirmed summary judgment for the officers solely on the basis that the seizures fell within a freestanding “community caretaking exception” to the warrant requirement it extrapolated from Cady. Writing for the unanimous court, Justice Thomas noted Cady’s “unmistakable distinction between vehicles and homes” and the Court’s repeated refusal to expand the scope of exceptions to the warrant requirement in the context of searches and seizures in homes. Finding that the First Circuit’s recognition of a freestanding community caretaking exception to the warrant requirement went “beyond anything this Court has recognized,” the Court vacated the judgment below and remanded for further proceedings.
Chief Justice Roberts, joined by Justice Breyer, concurred by noting that the Court’s opinion was not contrary to the exigent circumstances doctrine. Justice Alito concurred by noting his view that the Court correctly had rejected a special Fourth Amendment rule for a broad category of cases involving “community caretaking” but had not settled difficult questions about the parameters of all searches and seizures conducted for “non-law-enforcement purposes.” Justice Kavanaugh concurred and elaborated on his observations of the applicability of the exigent circumstances doctrine in cases where officers enter homes without warrants to assist persons in need of aid.
Edwards v. Vannoy, 593 U.S. ___, ___ S. Ct. ___ (May 17, 2021). Confronting the question in a habeas case of whether the holding in Ramos v. Louisiana, 590 U.S. ___, ___ S. Ct. ___ (2020) that a state jury must be unanimous to convict a criminal defendant of a serious offenses applies retroactively under the framework of Teague v. Lane, 489 U.S. 288 (1989), the Court held that while Ramos announced a “new” procedural rule it was not a “watershed rule” that applies retroactively. The Court further held that the Teague exception for watershed rules is moribund as no new rules of criminal procedure can satisfy the “purported exception” for watershed rules. Writing for the majority, Justice Kavanaugh first conducted the traditional analysis of retroactivity under Teague, finding that while Ramos announced a new procedural rule that was “momentous and consequential” it was not a “watershed” rule and therefore did not apply retroactively to cases on collateral review. Characterizing the “purported exception” for watershed rules as an “empty promise,” the Court said that “[c]ontinuing to articulate a theoretical exception that never actually applies in practice offers false hope to defendants, distorts the law, misleads judges, and wastes the resources of defense counsel, prosecutors, and courts.” The Court said it was time to say explicitly what had been apparent for years: “New procedural rules do not apply retroactively on federal collateral review.”
Justice Thomas, joined by Justice Gorsuch, concurred in full but wrote separately to explain that the case could have been resolved under the AEDPA because a Louisiana state court had considered Edwards’s argument that he was entitled to a unanimous jury verdict and had reasonably relied on federal law as it was prior to Ramos in rejecting that claim. Thomas explained that in such circumstances the AEDPA directs that a writ of habeas corpus shall not be granted.
Justice Gorsuch, joined by Justice Thomas, concurred by canvassing the history of the writ of habeas corpus, explaining developments in the law in the middle of the twentieth century leading to Teague, and expressing his agreement with the decision to explicitly state that the “watershed rule” exception was illusory.
Justice Kagan, joined by Justices Breyer and Sotomayor, dissented, stating her view that the holding of Ramos “fits to a tee Teague’s description of a watershed procedural rule” and criticizing the majority’s overturning of the watershed exception as following “none of the usual rules of stare decisis.”