71 F.4th 540
6th Cir.2023Background
- At ~5:00 a.m. after a blizzard in Lansing, MI, Officer Zolnai saw a running Chevy Malibu with driver Jaron Morgan appearing "passed out." He returned 11 minutes later and again observed Morgan unresponsive.
- Officer Zolnai parked ~15 feet away, turned on his body camera, did not activate emergency lights, and—without knocking, calling out, or shining a light—opened Morgan’s car door and asked if he was okay.
- Morgan was groggy; when asked for ID he moved his hand between the seat and console. The officer, fearing he might reach for a weapon, ordered Morgan out; Morgan resisted and a struggle ensued.
- After arresting Morgan, officers found fentanyl, methamphetamine, heroin, and cocaine on him and a semi-automatic pistol in a passenger-seat box. Morgan was indicted on drug and firearms charges.
- The district court denied Morgan’s suppression motion under the community-caretaking doctrine; Morgan conditionally pleaded guilty and reserved the right to appeal suppression. The Sixth Circuit reversed, holding the warrantless opening/unannounced seizure unreasonable, ordered suppression, vacated conviction and sentence, and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether opening a car door without warning and thereby seizing the occupant violated the Fourth Amendment | Morgan: Unlawful seizure—no exigency, no warning or less-intrusive measures taken | Government: Permitted under community-caretaking; officer legitimately checked for intoxication/overdose and feared sudden acceleration | Reversed—unreasonable. Caretaking did not justify unannounced door opening absent exigency or use of less-intrusive means |
| Whether evidence discovered after that entry must be suppressed | Morgan: Evidence is fruit of unconstitutional seizure and must be suppressed | Government: Evidence admissible because officers acted reasonably under caretaking exception | Suppressed. No other valid justification offered; conviction and sentence vacated |
Key Cases Cited
- Caniglia v. Strom, 141 S. Ct. 1596 (2021) (limits on community-caretaking entry into the home)
- Cady v. Dombrowski, 413 U.S. 433 (1973) (recognition of community-caretaking functions in automobile context)
- South Dakota v. Opperman, 428 U.S. 364 (1976) (police inventory and caretaking circumstances)
- Carroll v. United States, 267 U.S. 132 (1925) (automobile exception to the warrant requirement)
- Whren v. United States, 517 U.S. 806 (1996) (traffic-stop standards)
- Pennsylvania v. Mimms, 434 U.S. 106 (1977) (officers may order drivers out of vehicles during lawful stops)
- Arizona v. Gant, 556 U.S. 332 (2009) (limits on vehicle searches incident to arrest)
- California v. Carney, 471 U.S. 386 (1985) (reduced expectation of privacy in vehicles)
- Griffin v. Wisconsin, 483 U.S. 868 (1987) (reasonableness and special needs beyond ordinary law enforcement)
- United States v. Rohrig, 98 F.3d 1506 (6th Cir. 1996) (reasonableness—not requiring exhaustion of all alternatives)
- United States v. Coffee, 434 F.3d 887 (6th Cir. 2006) (standard of review for denial of suppression motion)
- United States v. Washington, 573 F.3d 279 (6th Cir. 2009) (caretaking permissibility tied to preventing imminent harm)
- United States v. See, 574 F.3d 309 (6th Cir. 2009) (suppression required when government offers no other justification)
- United States v. Lewis, 869 F.3d 460 (6th Cir. 2017) (caretaking entry into vehicle reasonable when actions matched the caretaking task)
- Taylor v. City of Saginaw, 922 F.3d 328 (6th Cir. 2019) (limits on use of evidence obtained during caretaking functions)