Scott Randall v. State of Indiana
101 N.E.3d 831
Ind. Ct. App.2018Background
- On July 29, 2016, Deputy Ashley Rose observed Scott Randall slumped over the steering wheel of a car in a hospital same‑day surgery lot; the driver’s door was open and Rose performed a welfare check.
- Rose illuminated the scene with overhead white lights and pulled behind the vehicle; Randall abruptly exited and approached Rose’s vehicle, was ordered back to his car, and Rose then spoke to him at the open driver’s door.
- Rose observed rapid speech, heavy sweating, nervous movements, and a small folded square of aluminum foil on the dash, which Rose associated with narcotics use.
- Rose asked what else in the vehicle he would not want a K‑9 to find; Randall admitted a marijuana pipe, refused to exit, was restrained with a wristlock while another officer aimed a taser, then cried and blurted that meth was in the door; officers observed a bag of white powder in the door pocket.
- Randall was charged with possession of methamphetamine and paraphernalia, moved to suppress the evidence, the trial court denied suppression relying on the community caretaking function, and Randall obtained interlocutory appeal.
- The Court of Appeals held the trial court erred to the extent it relied on the community‑caretaking doctrine, but affirmed denial of suppression because the seizure was justified by the emergency‑aid exception and Miranda warnings were not required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether community caretaking justified the seizure | State: welfare check/community caretaking justified ordering Randall back to car and brief seizure | Randall: community caretaking inapplicable; seizure unreasonable | Court: community caretaking was erroneously applied; not the proper basis here |
| Whether the seizure was reasonable under the Fourth Amendment and Indiana Const. art. I, § 11 | State: officers had an objectively reasonable basis to believe emergency medical aid might be needed (emergency‑aid exception) | Randall: any emergency concern dissipated when he exited and approached, so seizure was unjustified | Court: seizure permissible under the emergency‑aid doctrine and art. I, § 11 (balancing high concern + low intrusion) |
| Whether Miranda warnings were required for Randall’s statements | Randall: statements elicited without Miranda and should be suppressed | State: encounter was not custodial for Miranda; akin to a brief traffic/Terry stop | Court: not custodial interrogation; Miranda not required; statements admissible |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishing custodial‑interrogation Miranda rule)
- Mincey v. Arizona, 437 U.S. 385 (emergency aid can justify warrantless actions to protect life)
- Michigan v. Fisher, 558 U.S. 45 (officer may act without a warrant when objectively reasonable belief that aid is needed)
- M.O. v. State, 63 N.E.3d 329 (Ind. 2016) (limits on emergency‑aid application where facts do not support continuing exigency)
- Cruz‑Salazar v. State, 63 N.E.3d 1055 (Ind. 2016) (opening a vehicle to render aid permissible where occupant unresponsive and circumstances objectively alarming)
- Bruce v. State, 375 N.E.2d 1042 (Ind. 1978) (emergency response justified warrantless search when officer encountered continuing emergency)
- Berkemer v. McCarty, 468 U.S. 420 (traffic/Terry stops are seizures but not ordinarily Miranda custodial)
- Litchfield v. State, 824 N.E.2d 356 (art. I, § 11 reasonableness factors)