State v. McCormickAnnotate this Case
After a jury trial, Defendant was convicted of first offense driving under the influence. Defendant filed a motion for a new trial, arguing that the trial court erred by denying his motion to suppress on the grounds that the warrantless seizure of his parked vehicle and the ensuing field sobriety tests were not supported by reasonable suspicion. The trial court denied the motion. The Court of Criminal Appeals affirmed, concluding that the arresting officer’s activation of his patrol car’s rear blue lights was an exercise of the community caretaking function and not a seizure.The Supreme Court affirmed, holding (1) the Court’s decision in State v. Moats, which held that the community caretaking doctrine is not an exception to the federal and state constitutional warrant requirements, was wrongly decided and is hearby overruled; (2) the community caretaking exception is an exception to the state and federal constitutional warrant requirements that may be invoked to validate as reasonable a warrantless seizure of an automobile; and (3) the community caretaking exception applies in this case.
Authoring Judge: Justice Cornelia A. Clark
Trial Court Judge: Judge David A. Patterson
We granted this appeal to reconsider our decision in State v. Moats, 403 S.W.3d 170 (Tenn. 2013), which held that the community caretaking doctrine is not an exception to the federal and state constitutional warrant requirements. Having concluded that Moats was wrongly decided, we overrule Moats and hold that the community caretaking doctrine is analytically distinct from consensual police-citizen encounters and is instead an exception to the state and federal constitutional warrant requirements which may be invoked to validate as reasonable a warrantless seizure of an automobile. To establish that the community caretaking exception applies, the State must show that (1) the officer possessed specific and articulable facts, which, viewed objectively and in the totality of the circumstances, reasonably warranted a conclusion that a community caretaking action was needed; and (2) the officer s behavior and the scope of the intrusion were reasonably restrained and tailored to the community caretaking need. We conclude, based on the proof in the record on appeal, that the community caretaking exception applies in this case. Accordingly, the judgments of the trial court and Court of Criminal Appeals declining to grant the defendant s motion to suppress are affirmed on the separate grounds stated herein.