In the case of Caniglia v. Strom, Edward Caniglia's firearms were seized by police without a warrant following a wellness check on him at his home in 2015. The police had been called by Caniglia’s wife who was worried about her husband’s mental state after they had an argument and he produced an unloaded gun suggesting she shoot him to put him out of his misery. After ensuring that Mr. Caniglia posed no threat to himself or others, the officers nevertheless convinced his wife that he would be taken for a psychiatric evaluation and then proceeded to seize all firearms from their house without obtaining either Mr.Caniglia's consent or a warrant. However, contrary to what they told Mrs.Canigilia, the officers did not take her husband for any evaluation but instead left him at the hospital where he declined treatment and returned home immediately thereafter. Mr.Canigilia sued claiming violation of his Fourth Amendment rights against unreasonable searches and seizures arguing that neither consent nor exigent circumstances existed here which could have justified such seizure sans warrant.The District Court granted summary judgment in favor of respondents holding that removal fell within community caretaking exception while Circuit court affirmed this decision.

In the dissenting opinion for Caniglia v. Strom, Justice Clarence Thomas agreed with the majority that police officers violated Edward Caniglia's Fourth Amendment rights when they entered his home without a warrant and seized his firearms. However, he disagreed with their reasoning behind this decision. The majority based their ruling on the "community caretaking" exception to the Fourth Amendment's warrant requirement, which allows police to perform certain duties in community protection that are totally divorced from law enforcement’s detection, investigation or acquisition of evidence relating to violation of a criminal statute. But according to Justice Thomas, this case did not involve any form of “community caretaking,” as it was clearly an investigative act by police officers who suspected Mr.Caniglia might pose danger due to mental health issues after a domestic dispute incident rather than some sort of non-investigative public service.