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Description

Caniglia v Strom, (2021), was a United States Supreme Court case related to the Fourth Amendment to the United States Constitution's "community caretaking" exception.

Background.

During a heated argument in their home on August 20, 2015, Edward Caniglia grabbed a pistol from a bedroom and threw it on the dining room table. He then asked his wife, Kim, to shoot him with the gun. Although whether the gun was loaded or not was in dispute, Kim hid the gun and the magazine while Edward left for a "ride" after the fight due to concern for his mental condition. As conflict brewed up after Edward returned home, Kim stayed at a hotel. At the hotel, she phoned a furious Edward that night, who brought up topics from the fight. The next day, Kim was unable to reach Edward through any means of contact. She then decided to contact the Cranston, Rhode Island Police Department's non-emergency line because Kim feared he harmed himself after the tirades. Talking with Officer Mastrati, she mentioned the argument, Edward's behavior, and the firearm. Kim clarified that she was not in danger but worried that her husband was in danger. She was further afraid of what she might discover if she returned home. Mastrati called Edward, who agreed to meet with the police. Officers Mastrati, Smith, Russell, and Sergeant Barth met with him outside the Caniglia household. Kim was waiting nearby in her car. Barth observed Caniglia as appearing "agitated" and "angry" while Mastrati and Russell noted "calm," "cooperative," and "normal" behavior. Kim also remarked that Edward was upset that police were called. Sergeant Barth ultimately concluded that Edward posed a danger to himself and others. He then agreed with Barth's request to receive a psychiatric evaluation at a nearby hospital. According to Edward, he complied with the request only because the officers promised they would not confiscate his weapons if he sought treatment. On that same morning, one of the Caniglias informed police that another firearm was present in the home. Barth asked his superiors to confiscate the firearms, with Captain Henry approving the proposal. Kim directed the officers to the locations of the weapons, along with the magazines and associated ammunition. Police knew that Edward owned the items and did not want them seized. After multiple attempts to retrieve the firearms back from the police department, his lawyer requested in October 2015 that the guns be returned to Edward. Two months later, the firearms were returned. Shortly before getting the guns back, Edward sued the City of Cranston and the police department for violating his 4th Amendment rights.