State v. Anderson, 362 P.3d 1232

Around 10:00 p.m. in late December, Anderson was parked on the side of a rural highway with hazard lights on in very cold weather when two sheriff’s deputies pulled behind his car and activated their red-and-blue overhead lights.
Deputies exited their cruiser, approached Anderson, and asked if he needed assistance; they then asked him to exit the car and empty his pockets.
Deputies observed bloodshot eyes and that Anderson was unsure of his travel direction; he declined field sobriety tests but consented to a blood draw.
Deputies obtained a warrant to arrest Anderson, obtain blood/urine, and search his vehicle; blood tests showed no drugs but the vehicle search produced marijuana and paraphernalia.
Anderson moved to suppress the vehicle evidence as fruit of an unlawful seizure; the district court found the initial stop was a seizure but justified under the community caretaking doctrine and denied suppression.
The Utah Supreme Court reviewed whether the deputies’ activation of lights constituted a seizure and whether the seizure was reasonable as a community caretaking stop, and ultimately affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether deputies’ pulling behind a parked car with flashing lights constituted a Fourth Amendment seizure	Anderson: lights + parking = seizure; he was not free to leave	State: overhead lights can be used for safety and would not necessarily signal detention	Court: A reasonable person would feel detained; this was a seizure
Whether the seizure was justified by community caretaking	Anderson: seizure was unreasonable; evidence should be suppressed	State: stop aimed to check welfare in cold, dark conditions; caretaking justified brief detention	Court: seizure was reasonable under community caretaking and justified the initial stop
Validity of the Warden “imminent danger to life or limb” test for caretaking stops	Anderson: urged suppression under existing Warden standard	State: argued Warden’s requirement is too restrictive	Court: Warden’s “life or limb” requirement abandoned as inconsistent with Supreme Court emergency-aid cases
Whether evidence recovered was fruit of unconstitutional seizure requiring suppression	Anderson: later warrant/search flowed from illegal stop	State: stop was lawful, subsequent investigation and warrant were independent	Court: because the initial caretaking seizure was reasonable, evidence need not be suppressed

Cady v. Dombrowski, 413 U.S. 433 (1973) (establishes community caretaking doctrine for vehicle searches)
Brigham City v. Stuart, 547 U.S. 398 (2006) (emergency-aid exception allows warrantless entry to assist injured or threatened occupants)
Michigan v. Fisher, 558 U.S. 45 (2009) (emergency-aid does not require proof of life-threatening injury)
Brendlin v. California, 551 U.S. 249 (2007) (seizure determined by whether a reasonable person would not feel free to leave)
Provo City v. Warden, 875 P.2d 557 (Utah 1994) (Utah court of appeals’ caretaking formulation endorsed in 1994 but here limited and revised)
State v. Morris, 72 P.3d 570 (Kan. 2003) (collects authority concluding activation of emergency lights behind parked car effects a seizure)