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expressly disclaimed the possibility that they were SEARCH & SEIZURE Probable cause/Reasonable
reacting to a crime. The court also declined to consider suspicion.
whether any recognized exigent circumstances were
present because respondents had forfeited the point. “This is where it gets good, man.” This was Chimene
Nor did it find that respondents’ actions were akin to Hamilton Onyeri’s response to questions regarding
what a private citizen might have had authority to do if charges pending against him for violent crimes. For
petitioner’s wife had approached a neighbor for Onyeri, criminal activity coalesced into daily life.
assistance instead of the police. Rather than obtain gainful employment to support
himself, he engaged in a pattern of criminal conduct.
Neither the holding nor logic of Cady justified that And this pattern ultimately caught up to him when he
approach. True, Cady also involved a warrantless attempted to assassinate a Texas state judge. Onyeri
search for a firearm. But the location of that search was appeals one count of his conviction for this pattern,
an impounded vehicle—not a home—“‘a constitutional namely his conviction for conspiring to violate the
difference’” that the opinion repeatedly stressed. In Racketeer Influenced and Corrupt Organizations Act
fact, Cady expressly contrasted its treatment of a vehicle (“RICO”), 18 U.S.C. § 1962(d). Substantively, he
already under police control with a search of a car alleges three issues on appeal. For the reasons set forth
“parked adjacent to the dwelling place of the owner.” below, we affirm the judgment of the district court on all
Cady’s unmistakable distinction between vehicles and issues.
homes also places into proper context its reference to
“community caretaking.” This quote comes from a Onyeri’s criminal activities involved a multitude of
portion of the opinion explaining that the “frequency misdeeds that spanned almost half a decade. Pertinent to
with which . . . vehicle[s] can become disabled or this appeal is his criminal misconduct from late 2011 to
involved in . . . accident[s] on public highways” often 2015, the years during which Onyeri gathered and led
requires police to perform noncriminal “community his associates to engage in racketeering activity, which
caretaking functions,” such as providing aid to he cavalierly nicknamed the “Chimene, Incorporation.”
motorists. But, this recognition that police officers Because of the nature of Onyeri’s challenges on appeal,
perform many civic tasks in modern society was just a summary of some of the evidence adduced at his trial
that—a recognition that these tasks exist, and not an aids our discussion.
open-ended license to perform them anywhere.
What is reasonable for vehicles is different from what is Onyeri recruited his friend Bernard Akwar to assist him
reasonable for homes. Cady acknowledged as much, in stealing credit card numbers through the use of a
and this Court has repeatedly “declined to expand the skimmer. As they perfected their craft, Onyeri also
scope of . . . exceptions to the warrant requirement to brought Henry Yehe into the enterprise, and Yehe would
permit warrantless entry into the home.” We thus vacate steal gift cards from the various stores they visited.
the judgment below and remand for further proceedings Next, the conspirators would emboss the stolen credit
consistent with this opinion. card numbers onto the stolen gift cards and then encode
It is so ordered. the gift cards with the same credit card information.
They converted these gift cards into cash by using them
Caniglia v. Strom, U.S. Supreme Court, No. 20-157, to purchase electronics and then selling the electronics
May 17th, 2021. for cash, or by using them to buy legitimate gift cards.
******************************************** Onyeri also engaged a bank employee to open a bank
account for them using stolen identities. The
conspirators placed some of their proceeds into that
account.

Emboldened by their successes, Onyeri and Akwar also
stole identities—“[n]ames, socials, and dates of
birth”—to fabricate tax returns. They connected with
Sherica Price, who would file the fraudulent returns for
them. And, in the course of this scheme, they sought the

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