State v. Button, 86 A.3d 1001

Defendant Button challenges a warrantless stop under the community caretaking doctrine.
At ~11:28 p.m. on Nov. 19, 2011, Button’s car was observed on Perley Road by Trooper Riggen; no violations were seen initially.
The trooper followed Button for some distance; Button pulled to the right and stopped with engine and lights on in a low-traffic, rural area.
There were no signs of distress, no observed vehicle defects, and Button did not exit the vehicle or signal for help.
After about 30 seconds, the trooper activated blue lights to investigate, leading to Button’s DUI arrest; motion to suppress was denied based on community caretaking.
Button appealed, arguing the stop was not justified as caretaker activity and violated due process under state and federal constitutions; the court reverses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was justified by the community caretaking doctrine	Button: no distress indicia; caretaking lacks objective basis	Button: caretaking appropriate due to potential distress after stopping	Reversed; stop not justified

State v. Burgess, 163 Vt. 259 (1995) (seizure requires reasonable suspicion; caretaking narrow and contextual)
State v. Edwards, 2008 VT 23 (2008) (caretaking requires specific indicia of distress; not automatic)
State v. Marcello, 157 Vt. 657 (1991) (principle that caretaking must be reasonable and not invade privacy)
State v. Jestice, 2004 VT 65 (2004) (remark: nighttime idling in a busy lot insufficient for caretaking stop)
State v. Theetge, 171 Vt. 167 (2000) (stop may be justified when driver is parked in unsafe location)
State v. Campbell, 173 Vt. 575 (2001) (emergency or distress signals can justify caretaking in stormy/night scenarios)