William McNeal v. State of Indaina
62 N.E.3d 1275
| Ind. Ct. App. | 2016Background
- Officer Helton found a man (Kemo) unresponsive on a public sidewalk; while checking Kemo, McNeal approached and displayed signs of severe impairment (sweating, glazed/red eyes, slurred speech, unsteady gait) and repeatedly fell.
- Helton asked McNeal to sit for his safety; McNeal refused and kept attempting to leave, so Helton handcuffed him to keep him seated until medics arrived.
- While detaining McNeal for medical/caretaking reasons, Helton ran McNeal’s ID, discovered an outstanding arrest warrant, arrested him, and found three baggies of cocaine in a search incident to arrest.
- McNeal moved to suppress, arguing the detention violated the Fourth Amendment and Article 1, Section 11 (Indiana Constitution); the trial court denied the motion and convicted him after a bench trial of level 5 felony possession of cocaine.
- On appeal McNeal argued the initial consensual encounter became an unlawful investigative detention, rendering the cocaine inadmissible as fruit of the poisonous tree.
- The Court of Appeals affirmed, holding (1) the detention was a lawful exercise of the police community‑caretaking function and (2) alternatively, the officer had reasonable suspicion of public intoxication.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the officer’s detention violated the Fourth Amendment | McNeal: consensual encounter was converted into an unlawful investigative detention lacking reasonable suspicion, so evidence should be suppressed | State: detention was lawful—either caretaking or supported by reasonable suspicion of public intoxication | Court: detention reasonable under community‑caretaking; alternatively, reasonable suspicion existed; no Fourth Amendment violation |
| Whether detention violated Article 1, Section 11 of Indiana Constitution | McNeal: state constitution independently protects against this seizure; detention unreasonable under totality of circumstances | State: detention reasonable under Indiana standards for warrantless detentions (caretaking or reasonable suspicion) | Court: under Indiana law detention was reasonable; no violation of Article 1, Section 11 |
Key Cases Cited
- Cady v. Dombrowski, 413 U.S. 433 (1973) (recognizing police community‑caretaking function as limited exception to warrant requirement)
- Brigham City v. Stuart, 547 U.S. 398 (2006) (officer’s subjective motivation irrelevant when action is objectively reasonable under the Fourth Amendment)
- State v. Kramer, 759 N.W.2d 598 (Wis. 2009) (adopting three‑prong test to evaluate community‑caretaking seizures)
- Mitchell v. State, 745 N.E.2d 775 (Ind. 2001) (Indiana courts interpret Article 1, Section 11 independently from federal Fourth Amendment jurisprudence)
- Fair v. State, 627 N.E.2d 427 (Ind. 1993) (describing breadth of police community‑caretaking responsibilities)