State v. Morales, 363 P.3d 1133

At ~2:34 a.m. on a rural county road, Officer Vogt observed Morales' vehicle stopped on the shoulder with headlights on; no traffic violations were observed.
Vogt testified he was concerned the car might be disabled or involved in rural criminal activity and pulled in behind the vehicle and had dispatch run the license plate.
As Vogt approached, he saw brake lights activate and then activated his emergency lights to make contact; he smelled alcohol when speaking with Morales.
Morales performed field sobriety tests (failed one, passed another) and failed a preliminary breath test; he was charged with DUI.
Morales moved to suppress evidence from the stop as an unlawful seizure; the State defended the stop as a public safety (community caretaking) stop.
The trial court granted the suppression motion; the appellate court affirmed, holding the stop was not a bona fide community caretaking/public safety stop because the officer lacked specific, articulable facts and the sheriff’s policy had an investigatory component.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was a lawful public safety/community caretaking stop justifying the seizure without a warrant	Morales: The stop was an investigatory detention cloaked as a public safety stop and lacked specific, articulable facts to justify a welfare-based stop	State: Officer acted under community caretaking/public safety authority based on vehicle location, time, and rural setting; running the tag and activating lights fit accepted caretaking actions	Court: Stop invalid — officer lacked objective, specific, articulable facts; policy's investigatory prong and running the plate defeat public-safety justification; suppression affirmed

Cady v. Dombrowski, 413 U.S. 433 (1973) (origin of community caretaking exception allowing warrantless actions to protect public safety)
Nickelson v. Kansas Dept. of Revenue, 33 Kan. App. 2d 359 (2004) (public safety stop upheld where officer had multiple specific reasons to check stranded motorist)
State v. Gonzales, 36 Kan. App. 2d 446 (2006) (articulates three-step test for public safety stops and limits on post-assurance seizure)
State v. Marx, 289 Kan. 657 (2009) (public safety rationale cannot be used as pretext for investigative detention)
City of Topeka v. Grabauskas, 33 Kan. App. 2d 210 (2004) (community caretaking must be divorced from criminal investigation)
State v. Vistuba, 251 Kan. 821 (1992) (recognizes safety-based vehicle stops when supported by specific and articulable facts)
State v. Reiss, 299 Kan. 291 (2014) (standard of review for suppression rulings)
State v. Kurth, 813 N.W.2d 270 (Iowa 2012) (running a plate before a welfare stop is inconsistent with a public safety purpose)