Page 14 - PCPA Spring 2026 Bulletin Magazine

CHRIS BOYLE'S LEGAL UPDATE:
UNITED STATES V. RONK, 2025 U.S. DIST. LEXIS 214309
Chris Boyle's Legal Update
By: Chris Boyle, Esq., Chris Boyle Law Enforcement Consulting, LLC
COMMENT: The United States Supreme
Court gets this one absolutely right. (It may
surprise you to read that they don’t always
consult ME before so holding.) Anyway,
this is one that comes up frequently when
I am speaking to officers throughout the
Commonwealth – what exactly is our burden
for entry when we believe someone needs
emergency assistance? “OBJECTIVELY
REASONABLE BASIS FOR BELIEVING”,
that’s what, exactly. We should always be
working our way through the question of
“What do I have NOW?” at each step, but you
will see here that the Montana officers had
an objectively reasonable basis for believing
that a homeowner intended to take his own
life or had done so. Finally, don’t let it escape
your attention, gentle readers, that the
troops called for the Chief before going in
and he/she was up to the task. Forewarned
is forearmed! Be well and stay safe everyone.
Chris “The Chump” Boyle
Christopher P. Boyle, Esq.
LT. CHRISTOPHER BOYLE #125 (RET.)
is a fifth-generation Police Officer and
attorney. He spent the first sixteen
years of his professional life with the
Philadelphia Police Department, retiring
as a Lieutenant. The next sixteen years
were spent training, consulting for, and
defending Police Officers and their
Departments as a Trial Attorney and Law
Enforcement Expert. In 2020, Chris formed
“Chris Boyle Law Enforcement Consulting,
LLC” to provide training, subject matter
expertise and consultation services to law
enforcement and the legal profession. He
is a nationally recognized law enforcement
expert, frequently called upon to deliver
seminars and other training on a variety of
topics. He is also a proud member of the
Pennsylvania Chiefs of Police Association
who can be reached at: ChrisBoyle125@
ChrisBoyleConsulting. com or (215) 919-
7879. The material in this law alert has
been prepared by Chris Boyle. It is solely
intended to provide information on recent
legal developments and is not intended to
provide legal advice for a specific situation
or to create an attorney-client relationship.
Case v. Montana
Supreme Court of the United States
October 15, 2025, Argued; January 14, 2026, Decided
No. 24-624.
State v. Case, 2024 MT 165, 417 Mont. 354, 553 P.3d
985, 2024 Mont. LEXIS 855 (Aug. 6, 2024)
Disposition: 2024 MT 165, 417 Mont. 354, 553 P. 3d
985, affirmed.
Opinion by: KAGAN
OPINION
PA CHIEFS OF POLICE ASSOCIATION
Reporter
2026 U.S. LEXIS 432 *; 2026 LX 97314
Notice: The pagination of this document is subject to
change pending release of the final published version.
Prior History: [*1] ON WRIT OF CERTIORARI TO THE
SUPREME COURT OF MONTANA
JUSTICE KAGAN delivered the opinion of the Court.
HN1[] In Brigham City v. Stuart, 547 U. S. 398, 400,
126 S. Ct. 1943, 164 L. Ed. 2d 650 (2006), this Court held
that police officers may enter a home without a warrant if
they have an “objectively reasonable basis for believing”
that someone inside needs emergency assistance. The
question presented is whether that standard means that
officers must have “probable cause” for the intrusion, as
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