State v. McDowell
1510008837
| Del. Super. Ct. | Oct 31, 2016Background
- On Oct. 14, 2015 Cpl. Page encountered John McDowell beside a disabled vehicle blocking the right lane of Route 1; a passerby said the car had run out of gas.
- McDowell initially moved around the scene and then conversed with Cpl. Page; Page smelled alcohol and observed flushed face and glassy eyes.
- McDowell gave inconsistent answers about how the car ran out of gas, where purchased items were, and admitted drinking a glass of wine about 30 minutes earlier; a bottle of wine was in the passenger floor.
- Page conducted brief cognitive tasks and field sobriety-type questions; McDowell performed poorly and could not produce license/registration; a portable breath test was administered.
- After pushing the car to safety and calling a tow, Page placed McDowell in the police cruiser at 3:33 p.m., transported him to the station, and charged him with DUI; total encounter ~20 minutes.
- Procedurally: McDowell moved to suppress evidence arguing (1) unlawful seizure/overdetention beyond a community-caretaker stop and (2) custodial interrogation without Miranda warnings; the court denied the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of initial stop | Page lawfully rendered aid under community-caretaker doctrine | McDowell contends he was seized unlawfully and detained longer than caretaker stop permitted | Stop was justified as community-caretaker; not an unreasonable seizure |
| Extension to DUI investigation | N/A (State) — Page developed suspicion from odor, appearance, confusion and poor responses | McDowell argues investigation exceeded caretaking scope without reasonable suspicion | Transition lawful: officer had reasonable, articulable suspicion to investigate DUI |
| Probable cause for arrest | N/A (State) — observations, admissions, failed tests, and wine evidence supported arrest | McDowell challenges sufficiency of probable cause | Probable cause existed to arrest for driving under the influence |
| Miranda custodial requirement | N/A (State) — statements admissible because not custodial | McDowell argues statements about drinking and motive to buy wine should be suppressed for lack of Miranda | Not in custody during the stop/interview; Miranda not required; statements admissible |
Key Cases Cited
- Williams v. State, 962 A.2d 210 (Del. 2008) (adopts and explains community-caretaker exception and its three elements)
- Moore v. State, 997 A.2d 656 (Del. 2010) (explains transition from caretaking encounter to investigatory stop when officer observes conduct suggesting criminal activity)
- Loper v. State, 8 A.3d 1169 (Del. 2010) (defines custody for Miranda purposes under totality of circumstances standard)
- Berkemer v. McCarty, 468 U.S. 420 (1984) (ordinary traffic stops are typically noncustodial for Miranda purposes)
- Miranda v. Arizona, 384 U.S. 436 (1966) (establishes requirement to advise suspects of rights prior to custodial interrogation)