State of Iowa v. Terry Lee Coffman, 16-1720

Around 1:00 a.m., Story County Deputy Nick Hochberger observed Terry Coffman’s car stopped on the shoulder of a rural highway with brake lights engaged and no nearby assistance.
Deputy Hochberger activated his red-and-blue lights, pulled behind the vehicle, approached the driver’s window, and asked if the occupants were okay.
Coffman said his wife had a neck issue; the deputy detected the odor of alcohol, observed red/watery eyes, and Coffman admitted drinking four beers.
Hochberger administered three field sobriety tests, which Coffman failed; Coffman refused a breath test after implied-consent warnings.
Coffman was charged with first-offense OWI and moved to suppress evidence obtained after what he alleged was an unlawful, warrantless seizure. The district court denied suppression; Coffman appealed.
The court of appeals held the initial stop was a bona fide community-caretaking/public-servant welfare check and therefore a reasonable seizure under the Fourth Amendment, affirming the conviction.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Coffman)	Held
Whether the deputy’s activation of lights and approach constituted a constitutional seizure justified by the community-caretaking doctrine	The stop was a legitimate community-caretaking/public-servant welfare check of motorists stopped on a dark rural shoulder, justifying the warrantless seizure	The stop was an investigatory seizure lacking exigency or consent; community-caretaking does not authorize this intrusion	Held: Yes. The stop was a bona fide community-caretaking/public-servant seizure justified by public safety concerns
Whether the emergency-aid branch of the doctrine justified the seizure	N/A — State relied mainly on public-servant rationale	No immediate, serious emergency existed to justify the seizure under the emergency-aid doctrine	Held: No — facts did not support the emergency-aid exception
Whether the intrusion was unreasonable after balancing public need against privacy	Public interest in roadway safety and potential need for assistance outweighed the limited intrusion of a welfare check	The seizure was more intrusive than necessary; deputy could have checked without activating lights/seizing vehicle	Held: Balance favors State — minimal intrusion relative to public safety justified the stop

Cady v. Dombrowski, 413 U.S. 433 (established community-caretaking doctrine as distinct from criminal investigation)
State v. Kurth, 813 N.W.2d 270 (Iowa 2012) (reasonableness under community-caretaking evaluated case-by-case; limits on intrusion)
State v. Crawford, 659 N.W.2d 537 (Iowa 2003) (articulated three facets of community-caretaking: emergency aid, impoundment/inventory, public-servant)
State v. Mitchell, 498 N.W.2d 691 (Iowa 1993) (police public-safety duties extend beyond crime detection)
State v. Anderson, 362 P.3d 1232 (Utah 2015) (upheld community-caretaking stop of vehicle pulled to shoulder at night with hazard/brake lights)