State v. Grassrope, 970 N.W.2d 558

At 2:46 a.m. Sioux Falls dispatch received a call from a six‑year‑old who told them “daddy was being mean to mom”; when dispatch asked the mother if there was an emergency she hung up. The child later said his father was leaving to go to his car.
Officer Conley responded to the apartment building and, shortly after arrival, saw a tan Chevy Malibu leaving the lot; he did not yet have a vehicle description. Dispatch then updated that the father’s car was silver. Conley followed and initiated a traffic stop at 2:49 a.m.
Daniel Grassrope was the sole occupant; Conley smelled a strong odor of intoxicants and ultimately arrested Grassrope for DUI and driving with a suspended license.
Grassrope moved to suppress evidence, arguing the stop violated the Fourth Amendment because there was no reasonable suspicion or probable cause. The State defended the stop principally under the community caretaker exception.
The magistrate court granted the motion to suppress, finding no traffic violation, no report that anyone was leaving or requesting help, and that the child’s report did not support stopping a vehicle as a community‑caretaker measure.
The Supreme Court of South Dakota affirmed, holding the community caretaker exception did not justify the stop under the circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the community caretaker exception justified the warrantless stop	Conley acted reasonably as a community caretaker based on the child’s report of a domestic disturbance and the driver leaving the residence	No caretaking basis existed to stop a vehicle; the call gave no indication anyone needed aid or was leaving, so stop was an unlawful seizure	Court: Community caretaker exception did not apply; suppression affirmed

Cady v. Dombrowski, 413 U.S. 433 (recognizing law enforcement’s community caretaking functions and permitting certain warrantless vehicle searches)
State v. Rinehart, 617 N.W.2d 842 (S.D. 2000) (community caretaker stop justified when vehicle behavior suggested medical emergency or malfunction)
State v. Short Bull, 928 N.W.2d 473 (S.D. 2019) (officer’s stop of a vehicle potentially carrying a domestic‑disturbance victim fell within community caretaker exception)
State v. Kleven, 887 N.W.2d 740 (S.D. 2016) (caretaker justification for approaching a parked car with running engine and an apparently unconscious occupant)
Caniglia v. Strom, 141 S. Ct. 1596 (U.S. 2021) (limits community‑caretaker doctrine as a standalone basis for warrantless home searches but affirms exigent‑circumstances aid principles)