State v. Spaulding, 2011 MT 204

Spaulding pleaded guilty to misdemeanor DUI per se in Carbon County; she reserved the right to appeal the denial of her suppression motion.
At about 1:25 a.m. on a remote back road, Deputy Croft followed Spaulding’s vehicle after it abruptly pulled over about 200 yards ahead of him.
Croft had no particularized suspicion or grounds for an investigatory stop; his stop was premised on welfare considerations (possible lost motorist, mechanical failure, or medical emergency).
Spaulding had two passengers; Croft smelled alcohol from the vehicle after making contact and decided to conduct a DUI investigation with particularized suspicion.
The District Court found objective, specific, articulable facts supported a welfare check under the community caretaker doctrine given the time, temperature, location, and abrupt stop on a desolate road.
Spaulding challenged the stop as unlawful seizure; the court ultimately held the community caretaker doctrine justified the seizure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Spaulding was subjected to a seizure	Spaulding argues there was an unlawful seizure under Fourth Amendment standards	Spaulding contends the stop was a non-seizure welfare check under the community caretaker doctrine	Yes, Spaulding was temporarily seized; the seizure was governed by the community caretaker test
Whether the community caretaker doctrine applied here	Spaulding asserts doctrine does not apply given lack of danger signals	Spaulding argues the facts fit a welfare check based on time, location, and abrupt stop	Yes, the doctrine applied; objective facts supported a welfare check and reasonable seizure

State v. Lovegren, 310 Mont. 358 (2002 MT 153) (establishes community caretaker framework and objective facts test)
State v. Seaman, 329 Mont. 429 (2005 MT 307) (recognizes welfare checks and limits on pretextual stops)
State v. Wilkins, 350 Mont. 96 (2009 MT 99) (refines community caretaker applicability)
Graham v. State, 340 Mont. 366 (2007 MT 358) (articulates three-part community caretaker test)
Lovegren, 310 Mont. 358 (2002 MT 153) (embedded in discussion of objective facts for welfare checks)
State v. Reiner, 317 Mont. 304 (2003 MT 243) (limits on welfare-check justification when stop is primarily investigatory)
State v. Nelson, 319 Mont. 250 (2004 MT 13) (factors for evaluating welfare-check stops)
State v. Wheeler, 331 Mont. 179 (2006 MT 38) (community caretaker doctrine applications)
State v. Litschauer, 330 Mont. 22 (2005 MT 331) (fact-specific application of welfare-check doctrine)
Brown v. State, 349 Mont. 408 (2009 MT 64) (limits on interpreting officer experience in reasonable-inference analysis)
Murray, 322 Mont. 47 (2004 MT 169) (dialogue on reasonable suspicion standards post-Mendenhall)