This episode of the Guardian Mindset Podcast with Attorney Eric Daigle breaks down the Supreme Court’s Case v. Montana decision and what it means for welfare checks, mental health calls, and warrantless entry into a home. Learn when officers can act without a warrant and how to apply the emergency aid exception the right way.

Legal Standards for Emergency Aid Entry
The recent Supreme Court case, Case v. Montana, examined whether law enforcement could enter a home without a warrant based on less than probable cause regarding an emergency. The court held that officers may do so if they possess an objectively reasonable belief that an occupant is in serious danger or needs assistance. This ruling clarifies the Fourth Amendment’s emergency aid exception, reinforcing that a reasonable basis standard suffices, thus diverging from a probable cause requirement typically seen in criminal contexts.

Implications for Law Enforcement
This decision has significant implications for law enforcement’s response to welfare checks, mental health crises, and other emergencies. It emphasizes the importance of acting swiftly when a reasonable belief of imminent danger exists. The case underscores the need for officers to be equipped with adequate training and policies that address emergency situations. Officers should document the rationale for their entry and ensure their actions remain focused solely on resolving the emergency without infringing on the Fourth Amendment rights regarding unwarranted searches.

Policy and Practice Recommendations
To comply with this ruling, police departments should revise their policies to state that officers can enter a residence without a warrant when they have specific and articulable facts indicating a person is in danger or requires aid. Officers must limit their actions to the emergency at hand and avoid using such entries as a means to conduct general searches for evidence. Documentation of all relevant factors surrounding the incident is crucial, including the emergency’s nature and how it was resolved. Additionally, enhancing collaboration with mental health professionals during crisis responses is recommended to improve outcomes for individuals in distress.

Core Points:

• The Supreme Court clarified that officers can enter a home without a warrant if they have an objectively reasonable belief that someone is seriously injured or in imminent danger.
• The emergency aid exception does not require probable cause but a reasonable basis for belief in an emergency situation.
• Officers must document specific facts indicating an emergency, the source of information, and actions taken upon entry.
• The court emphasized that entries must be limited to addressing the emergency and cannot be used as a pretext for criminal investigations.
• Police agencies should update policies to align with the clarified standards and incorporate proper training for handling welfare checks and mental health crisis calls.

Continue Your Education: https://dlglearningcenter.com/scotus-affirms-standard-for-emergency-aid-entry-into-the-home-in-case-v-montana/

• (00:00:00) - Fourth Amendment Emergency Aid Case
• (00:02:24) - Exigent circumstances search under the Fourth Amendment
• (00:05:28) - Supreme Court: Warrantless Entry Into a Home Without a Warrant
• (00:21:33) - Emergency Entry Rule

The Guardian Mindset Podcast, hosted by Attorney Eric Daigle, discusses the critical issues surrounding prone restraint deaths, moving beyond outdated notions of positional asphyxia to focus on metabolic acidosis and its implications. This episode’s guest, Geoffrey Thor Desmoulin, Ph.D., R.Kin., P.L.Eng., of GTD Scientific, emphasizes the need to recognize the complexities of physiology, biomechanics, and the law when addressing these incidents.

Key Takeaways:

• The concept of positional asphyxia is outdated; metabolic acidosis is a more relevant explanation for prone restraint deaths.
• Officers should recognize key risk factors such as obesity, drug use, anxiety, and prolonged struggle to identify individuals at risk.
• Time is critical; quicker restraints can mitigate risks associated with metabolic acidosis.
• Recovery positions should be encouraged, but sitting up is optimal for breathing efficiency.
• Collaboration between law enforcement, medical personnel, and researchers is essential for effective training and response protocols.

Metabolic Acidosis vs. Positional Asphyxia
Dr. Desmoulin explains that metabolic acidosis, characterized by the buildup of carbon dioxide in the body, is a more accurate explanation for deaths during prone restraint. This condition arises when individuals struggle against restraint, inhibiting their ability to breathe efficiently. He points out that conventional beliefs about weight on the back being inconsequential are misguided, as the physiological realities on the ground differ significantly from research findings.

Identifying Risk Factors
Key risk factors for officers to recognize include obesity, drug use, anxiety, and prolonged struggle. The podcast highlights that these factors compound the risk of deterioration in restrained individuals. The discussion underscores the importance of early recognition of these signs, advocating for a swift response that prioritizes medical assistance when necessary.

The Importance of Time and Recovery Positions
Dr. Desmoulin stresses the critical nature of time in managing restrained individuals. The faster officers can restrain a subject and transition them to a recovery position, ideally sitting up, the better their chances of preventing a metabolic crisis. While recovery positions are useful, sitting upright is deemed most effective for breathing.

Collaboration for Better Outcomes
Finally, the conversation highlights the need for law enforcement agencies to collaborate with medical professionals and researchers. This partnership is vital for developing training protocols that ensure officers are equipped to handle individuals in crisis effectively. By improving communication and understanding across these fields, they can enhance public safety and reduce the tragic outcomes associated with prone restraint incidents.

• (00:00:00) - Guardian Mindset: Posed Restraint Deaths
• (00:01:56) - Deadliest Warrior: The Law Enforcement Host
• (00:04:15) - The Use of Force: Explained
• (00:07:04) - What Do Most People Get Wrong About Praying Deaths?
• (00:10:04) - metabolic acidosis
• (00:13:38) - Risk Factors for Police on the Street
• (00:15:48) - Obesity and prone Restraint
• (00:20:09) - Critical Variables in Point Restraint
• (00:26:58) - Why Does Continuing to Struggle After Cuffing Matter?
• (00:31:29) - The Use of Force in Custody
• (00:34:06) - Discipline in the Police Training

In this episode, we break down several major Supreme Court cases headed into 2026 that could reshape law enforcement practices and Second Amendment enforcement, from warrantless home entries during emergencies to firearm restrictions on private property and drug-related gun bans. We’ll explain what’s at stake, what officers need to watch for, and how to protect cases through clear documentation and sound decision-making as the law continues to evolve.

Continue your education on the DLG Learning Center

Key Takeaways

• The Supreme Court is reviewing several key cases that may impact law enforcement procedures and Second Amendment rights in 2026.
• One significant case involves warrantless home entry during emergencies, raising questions about the level of certainty required for police intervention.
• Another case examines the legality of prohibiting licensed handgun carriers from bringing guns onto private property without express permission.
• A Third case addresses the Second Amendment implications of federal laws banning gun possession for habitual drug users.
• Law enforcement should document emergency facts meticulously, distinguish between trespass and firearm laws, and build strong cases for prosecution regarding drug use and gun possession.

Summary

Warrantless Home Entry

One of the most pressing cases on the Supreme Court’s docket involves warrantless home entry during emergency and welfare checks. This case questions how certain law enforcement must be regarding an emergency before entering a home without a warrant, focusing on the “emergency aid exception.” The core issue is whether a mere reasonable suspicion is enough for entry or if probable cause is required. This case’s outcome could significantly affect how officers respond to emergency situations, emphasizing the importance of documenting emergency facts and ensuring that entries remain narrowly tied to the circumstances.

Gun Carrying on Private Property

Another crucial case is Wilford v. Lopez, which scrutinizes Hawaii’s law that prohibits individuals from carrying firearms onto private property without the owner’s consent. The challengers argue this restriction violates Second Amendment rights. The Supreme Court’s decision could either reinforce states’ abilities to regulate firearm possession or limit such regulations. This ruling will directly impact law enforcement’s ability to enforce firearm restrictions in public areas and private properties, necessitating clear communication of current laws to officers and proper training on distinguishing between criminal trespass and lawful gun possession.

Drug Use and Gun Possession

The Supreme Court will also hear a case concerning the prohibition of firearm possession for habitual drug users. This case stems from a ruling that found the law potentially unconstitutional. Should the Court side with the challenger, it could eliminate significant barriers for certain individuals in possessing firearms, fundamentally altering the legal landscape surrounding gun ownership and drug use. For law enforcement, this necessitates thorough documentation of drug use patterns and timing in relation to gun possession, emphasizing the importance of a well-supported case for prosecution.

These cases highlight the evolving legal challenges faced by law enforcement, urging officers to stay informed and prepared to adapt to potential changes in the law as they unfold in 2026.

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About Daigle Law Group

Attorney Daigle focuses on evaluating and providing policy guidance and training on areas of increased liability for law enforcement agencies nationwide. His work emphasizes current trends in legal standards, operational practices, and community expectations, with particular...

• (00:00:00) - Welcome to 2026
• (00:02:02) - Upcoming Supreme Court Cases
• (00:03:10) - Case Spotlight: Warrantless Home Entry
• (00:09:48) - Guidance for Emergency Entries
• (00:09:58) - Second Amendment Challenges
• (00:15:25) - Gun Possession and Drug Use
• (00:21:21) - Building a Strong Case
• (00:26:06) - Looking Ahead: Hot Topics for 2026