State v. Anderson
362 P.3d 1232
| Utah | 2015Background
- Around 10:00 p.m. in late December, Anderson pulled his car onto the shoulder of a rural highway with hazard lights on; two sheriff’s deputies stopped and activated their cruiser’s red/blue lights behind his vehicle.
- Deputies approached, asked if he needed assistance; they briefly detained him (asked to exit, empty pockets) and noticed bloodshot eyes and disorientation about direction of travel.
- Anderson declined field sobriety tests but consented to a blood draw; deputies obtained a warrant to arrest, draw blood/urine, and search the vehicle.
- Blood tests showed no illegal substances, but the vehicle search produced marijuana and drug paraphernalia; Anderson was charged and moved to suppress the evidence as fruit of an unlawful seizure.
- The district court found a seizure occurred when deputies engaged overhead lights but held the stop was justified under the community caretaking doctrine; Anderson appealed to the Utah Supreme Court.
Issues
| Issue | Anderson's Argument | State's Argument | Held |
|---|---|---|---|
| Whether deputies’ activation of red/blue lights behind a parked car constituted a Fourth Amendment seizure | The lights and positioning constituted a show of authority that restrained a reasonable person, so a seizure occurred | A reasonable person would feel free to leave because lights could be for safety, not a command to stop | Yes — engaging overhead lights while pulling directly behind a parked car can constitute a seizure under the Fourth Amendment |
| Whether the seizure was justified under the community caretaking doctrine | The stop was not justified as caretaking and thus any evidence is fruit of an unlawful seizure | The stop was a minimal, safety-focused caretaking stop given time, cold, hazard lights, and location | The seizure was reasonable under an updated community caretaking standard and justified; suppression denied |
| Whether Utah’s Warden “imminent danger to life or limb” standard remains valid | (implicit) Warden’s stringent standard should apply to caretaking seizures | Warden’s standard is unduly restrictive and inconsistent with Supreme Court emergency-aid decisions | Abandoned Warden’s “life or limb” standard as inconsistent with later U.S. Supreme Court precedent |
| Proper standard for community caretaking seizures of motorists | N/A (Anderson challenges the stop under Fourth Amendment) | Courts should apply a balancing test weighing intrusion against public safety interest/exigency | Adopted a balancing test: evaluate degree of intrusion (authority/length) and seriousness/likelihood of need for aid; applied here and found seizure reasonable |
Key Cases Cited
- Cady v. Dombrowski, 413 U.S. 433 (1973) (recognizes community caretaking function justifying warrantless vehicle search)
- Brigham City v. Stuart, 547 U.S. 398 (2006) (emergency-aid doctrine permits warrantless entry to render aid or prevent imminent injury)
- Michigan v. Fisher, 558 U.S. 45 (2009) (officers need not have ironclad proof of a serious, life‑threatening injury to invoke emergency-aid)
- Brendlin v. California, 551 U.S. 249 (2007) (a person is seized when a show of authority would make a reasonable person believe they are not free to leave)
- Provo City v. Warden, 844 P.2d 360 (Utah Ct. App. 1992) (articulated a caretaking test requiring imminent danger to life or limb)
- Provo City v. Warden, 875 P.2d 557 (Utah 1994) (Utah Supreme Court endorsed court of appeals’ reasoning in result)
- State v. Morris, 72 P.3d 570 (Kan. 2003) (collects authority holding activation of emergency lights behind parked car constitutes seizure)