State v. J. Meacham, 2016 MT 334N

On Feb. 27, 2014 at ~10:30 p.m., Deputy Rebecca Birket found Meacham’s vehicle stuck in a snowbank behind a saloon and approached to render aid.
During the brief contact Meacham avoided eye contact, stared blankly, smelled of alcohol, had glassy/bloodshot eyes, and spoke with slurred speech; Meacham said he was "good."
As Deputy Birket inspected the rear of the vehicle, Meacham drove away; Birket pursued and Meacham was stopped by another officer.
Meacham admitted to drinking; Birket arrested him. Charges included felony DUI, obstructing a peace officer, and driving with a suspended/revoked license.
Meacham moved to suppress evidence and dismiss charges, arguing the contact became an unlawful seizure once he declined assistance and that Birket lacked particularized suspicion.
The District Court denied the motion, finding the initial contact lawful under the community caretaker doctrine and that Birket had developed particularized suspicion of DUI. The Supreme Court of Montana affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Meacham)	Held
Whether the officer’s initial contact was lawful under the community caretaker doctrine	Initial contact was a valid community-caretaker inquiry to check if Meacham needed help	Agreed initial contact was permissible (concedes community-caretaker initiation)	Court: Initial contact was lawful under community-caretaker doctrine
Whether officer’s further investigation/seizure after Meacham said he didn’t need assistance required separate justification, and if such justification existed	Officer had developed particularized suspicion (objective signs of intoxication) justifying seizure and pursuit	Argued caretaker function ended when he declined assistance; subsequent actions were an unlawful seizure lacking particularized suspicion	Court: Birket had particularized suspicion based on articulable facts (odor, slurred speech, bloodshot/glassy eyes, car stuck behind saloon at night); subsequent investigation was lawful; suppression/dismissal denied

State v. Spaulding, 361 Mont. 445, 259 P.3d 793 (recognizing limits of community caretaker doctrine and when further action becomes a seizure)
State v. Lovegren, 310 Mont. 358, 51 P.3d 471 (community caretaker doctrine permits stops to aid persons believed to be in peril)
Brown v. State, 349 Mont. 408, 203 P.3d 842 (requirements for particularized suspicion)
Brunette v. State, 383 Mont. 458, 372 P.3d 476 (articulable facts and reasonable inferences needed for particularized suspicion)
Hulse v. DOJ, Motor Vehicle Div., 289 Mont. 1, 961 P.2d 75 (officer observations like smell of alcohol, bloodshot/glassy eyes, slurred speech can establish suspicion of intoxication)
State v. Marcial, 371 Mont. 348, 308 P.3d 69 (similar facts supporting suspicion of DUI)
City of Missoula v. Moore, 360 Mont. 22, 251 P.3d 679 (standard of review for suppression rulings)
State v. Kant, 382 Mont. 239, 367 P.3d 726 (review standard for motions to dismiss in criminal cases)