Steven Davis v. United States
110 A.3d 590
D.C.2015Background
- Davis was convicted of possession of cocaine after a bench trial.
- The trial court denied Davis's motion to suppress two blue ziplock bags of cocaine found in his vehicle.
- Officer Smith entered Davis's running, unattended vehicle to move it out of the middle of a parking lot blocking traffic.
- The officer saw cocaine in plain view on the driver’s side floorboard and recovered it after entering the car.
- EMTs were attending to Davis when the officer entered the vehicle; Davis was assisted to the ambulance and later arrested.
- Davis argued the Fourth Amendment prohibited entering the car to move it and that the plain-view seizure should be suppressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether entry into the car was lawful under community caretaking. | Davis: entry improper since no basis to enter car or move it. | Davis: caretaking not applicable; could have waited or towed without entering. | Yes, entry reasonable under caretaking. |
| Whether the plain-view seizure was valid following lawful entry. | Davis: plain-view seizure invalid if entry unlawful. | Davis: no alternative basis for seizure; not a search for evidence. | Yes, seizure valid in plain view after lawful entry. |
Key Cases Cited
- Cady v. Dombrowski, 413 U.S. 433 (U.S. Supreme Court 1973) (establishes community caretaking and non-criminal entry rationales)
- South Dakota v. Opperman, 428 U.S. 364 (U.S. Supreme Court 1976) (permits incidental detention/removal of vehicles under caretaking function)
- Jones v. United States, 330 A.2d 248 (D.C. 1974) (caretaking function related to vehicle obstruction permitted)
- Sanchez, 612 F.3d 1 (1st Cir. 2010) (community caretaking allowed noncriminal entries to address safety)
- Carroway, 2013 WL 3329453 (N.J. Super. Ct. App. Div. 2013) (caretaking application to vehicle safety and obstruction cases)