Sanders v. United States

Summary

The Supreme Court granted, vacated, and remanded the case for reconsideration in light of Caniglia v. Strom, which rejected a standalone community-caretaking doctrine as a basis for warrantless entry into a home. Justice Kavanaugh concurred, explaining that the Eighth Circuit could still consider whether the entry was justified under precedents permitting warrantless entry when officers reasonably believe an occupant faces serious injury.

Holdings

1. Because the Eighth Circuit relied on a standalone community-caretaking doctrine to uphold the warrantless entry into the home, its judgment was vacated and the case was remanded for further consideration in light of Caniglia v. Strom.
2. On remand, the Eighth Circuit may consider whether the entry was justified under longstanding precedents permitting warrantless entry when officers have an objectively reasonable basis to believe an occupant is seriously injured or threatened with serious injury.

Questions Presented

1. Whether the Eighth Circuit's reliance on a standalone community-caretaking doctrine justified the warrantless entry into a home under the Fourth Amendment.
2. Whether the judgment should be vacated and remanded for reconsideration in light of Caniglia v. Strom.

Disposition

vacated