State v. McCormick

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. View "State v. McCormick" on Justia Law