State v. J. Meacham
2016 MT 334N
| Mont. | 2016Background
- Late evening, Feb. 27, 2014: Deputy Birket found Meacham's car stuck in a snowbank behind a saloon and approached to offer aid.
- On approach, Meacham avoided eye contact and stared straight ahead; when asked if he needed assistance he said, “I’m good.”
- During the brief contact Deputy Birket smelled alcohol and observed slurred speech and glossy, watery, red eyes.
- As Birket walked to the rear of the vehicle Meacham drove away; Birket pursued and another officer stopped him. Meacham admitted to drinking and was arrested.
- Meacham moved to suppress evidence and dismiss charges arguing that after he declined assistance the officer lacked particularized suspicion and any further detention was an unlawful seizure; the district court denied the motion and the Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officer’s contact and subsequent investigation were justified under the community caretaker doctrine or required particularized suspicion | State: Initial contact was lawful under community caretaker; officer developed grounds for investigation before any seizure | Meacham: Community caretaker function ended when he said he did not need help; further actions were an unlawful seizure absent particularized suspicion | Court: Community caretaker justified initial contact; officer had particularized suspicion based on observed signs of intoxication, so continued investigation was lawful |
| Whether the facts observed constituted particularized suspicion of DUI | State: Officer observed articulable, objective signs (odor of alcohol, slurred speech, bloodshot/glassy eyes, car stuck behind saloon at night) supporting suspicion | Meacham: Observations did not amount to particularized suspicion once he declined help | Court: Those objective signs met the Brunette/Brown standards for particularized suspicion of DUI |
| Whether evidence obtained after the contact should be suppressed | State: No suppression; investigatory actions were supported by particularized suspicion | Meacham: Evidence must be suppressed because subsequent restraint was an unlawful seizure | Court: Denial of suppression affirmed because actions were supported by particularized suspicion |
| Standard of review for denial of suppression/dismissal | State: District court’s factual findings reviewed for clear error; legal conclusions reviewed de novo | Meacham: N/A (relates to preservation of legal error) | Court: Affirmed use of clear-error for factual findings and de novo for legal conclusions |
Key Cases Cited
- State v. Spaulding, 361 Mont. 445 (recognizing limits of community caretaker doctrine; further action requires particularized suspicion)
- State v. Lovegren, 310 Mont. 358 (community caretaker doctrine permits stops to render aid)
- Brunette v. State, 383 Mont. 458 (particularized suspicion standard requires objective, articulable facts and reasonable inferences)
- Brown v. State, 349 Mont. 408 (articulable facts test for stops)
- Hulse v. DOJ, Motor Vehicle Div., 289 Mont. 1 (smell of alcohol, bloodshot/glassy eyes, slurred speech can establish suspicion of intoxication)
- State v. Marcial, 371 Mont. 348 (officer’s observation of alcohol odor plus other signs supported particularized suspicion of DUI)
- City of Missoula v. Moore, 360 Mont. 22 (standard of review for suppression motions)