The Utah Supreme Court provided an analysis of Fourth Amendment search and seizures issues in the case of State v. Smith, 2022 UT 13. The opinion provides a number of points and clarifications that can be very helpful to defense counsel in challenging police search and seizure conduct.
Facts of the Case
The defendant, Smith, was parked in a McDonald’s parking lot. Employees had asked him to leave, but he drove around the lot and re-parked. Employees called police who, on their arrival found him asleep in the parked car. Under the guise of a “welfare check,” police called for backup, used their patrol vehicles to block his car, and put a bright light in his eyes. Following their initial interactions, police searched his vehicle and eventually arrested him for DUI. All of this was done without a warrant.
District Court Proceedings
In the district court, Smith filed a motion to suppress objecting to the warrantless search and seizure. In responding to the motion to suppress, the State relied only on the community caretaking doctrine as justification for the police action.
The district court denied the defense motion to suppress, agreeing with the prosecution’s position on the community caretaker doctrine. Smith entered a plea, under the principles of State v. Sery, 758 P.2d 935 (Utah Ct. App 1988), reserving the right to appeal the court’s denial of the motion to suppress.
Court of Appeals Affirms the District Court
After full briefing and argument, the Utah Court of Appeals affirmed the district court’s denial of the motion to suppress. The defense filed a petition for writ of certiorari, asking the Utah Supreme Court to review and reverse the decision of the Court of Appeals.
Supreme Court Decision Reversing the Court of Appeals
The Supreme Court clarifies two main points in this opinion. First, warrantless searches and seizures are presumptively unreasonable, and the burden of proof rests with the prosecution to show otherwise. Second, the overall standard for justifying warrantless searches and seizures is reasonableness, even under the community care doctrine.
The Court found the police officers actions – calling backup, blocking him in, shining a bright light in his face – were not reasonable under the community caretaker doctrine where the primary concern is the safety of the individual or the community. Especially when the individual is just sleeping in a parked vehicle.