Clemons v. Couch

Relying on Caniglia, court holds that trooper who entered home without a warrant with estranged wife of son of homeowner to gather her things, over objection of homeowner, committed an unlawful entry; trooper denied qualified immunity although actions predated Caniglia, because previous 6th Circuit law held community caretaking exception to warrant requirement could not be applied except “when delay is reasonably likely to result in injury or ongoing harm to the community at large.