Mary Osborne v. State of Indiana, 63 N.E.3d 329

At ~1:00 AM a gas-station clerk reported a woman was "stuck underneath her vehicle" and provided the vehicle description and license plate; dispatch later reported she had gotten out and was leaving.
Officer Arnold, nearby on another call, saw a black BMW (Osborne) pulling out, made a U-turn, and followed without observing traffic violations or criminal activity.
Arnold initiated a traffic stop to check Osborne’s welfare, approached the vehicle, and observed no visible injury; Osborne explained she’d rolled backward from a manual-transmission car because the parking brake was not set.
During the encounter Arnold detected alcohol odor, observed signs of impairment, administered field sobriety tests and a portable breath test (0.12), leading to arrest; jail test returned 0.10.
Osborne moved to suppress evidence arguing the warrantless stop violated the Fourth Amendment and Article 1, Section 11 of the Indiana Constitution; the trial court denied the motion, Court of Appeals agreed with Osborne, and the Indiana Supreme Court granted transfer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless traffic stop was justified by an objectively reasonable belief medical assistance was needed (Fisher exception).	State: dispatch report of a woman trapped under a car justified a welfare stop to check for need of emergency aid.	Osborne: dispatch had updated that she was out and leaving; officer observed no ongoing emergency, so stop was unreasonable.	Stop was not justified under the medical-assistance exigency; State failed its burden.
Whether the stop falls within the broader community-caretaking exception.	State: officer acted as community caretaker to protect welfare.	Osborne: stop was purely welfare check of an individual, not a community-hazard caretaking function; community-caretaking should not be expanded here.	Court declined to extend community-caretaking to justify this stop.
Whether officer's subjective motive (welfare check) cures any Fourth Amendment defect.	State: officer genuinely sought to aid Osborne.	Osborne: subjective intent insufficient; objective reasonableness is the test.	Objective test controls; the facts did not support a reasonable belief of emergency.
Whether Indiana Constitution (Art. 1, § 11) independently permits the stop.	State: same rationale as federal analysis; stop reasonable under totality of circumstances.	Osborne: state-constitutional reasonableness factors do not support seizure here.	Stop was also impermissible under Article 1, § 11.

Michigan v. Fisher, 558 U.S. 45 (2009) (warrantless entry/seizure permissible when officer has objectively reasonable basis to believe medical assistance is needed)
Mincey v. Arizona, 437 U.S. 385 (1978) (Fourth Amendment does not bar warrantless entries when officers reasonably believe immediate aid is required)
Katz v. United States, 389 U.S. 347 (1967) (warrantless searches/seizures are presumptively unreasonable; exceptions must be shown)
Bruce v. State, 375 N.E.2d 1042 (Ind. 1978) (warrantless vehicle entry justified where circumstances indicated ongoing emergency)
Trotter v. State, 933 N.E.2d 572 (Ind. Ct. App. 2010) (no reasonable belief of emergency where officers lacked evidence occupant needed immediate aid)
Wilford v. State, 50 N.E.3d 371 (Ind. 2016) (discussing limited application of community-caretaking doctrine and strict standards for impoundment)
Campos v. State, 885 N.E.2d 590 (Ind. 2008) (traffic stops are seizures subject to Fourth Amendment constraints)