This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
On June 5, 2002, police officers investigated a single-vehicle accident involving a 1985 Chevrolet truck that had gone off the road and into a ditch. The driver was not present at the scene. A pickup truck with two occupants passed the accident site twice, prompting officers to stop it based on suspicion. The passenger admitted to owning and driving the wrecked truck and showed signs of intoxication. He was arrested after field sobriety tests and a blood test confirmed his blood alcohol concentration exceeded the legal limit (paras 2-4).
Procedural History
- District Court, Lincoln County: Denied the Defendant's motion to suppress evidence obtained from the vehicle stop and convicted him of driving while intoxicated (para 1).
Parties' Submissions
- Defendant-Appellant: Argued that the officers lacked reasonable suspicion to stop the vehicle, making the stop and subsequent evidence collection unconstitutional under the Fourth Amendment (paras 1, 5).
- Plaintiff-Appellee: Contended that the officers had reasonable suspicion based on the Defendant's behavior at the accident scene and alternatively argued that the stop was justified under the community caretaking exception (paras 5, 15-16).
Legal Issues
- Did the officers have reasonable suspicion to stop the vehicle in which the Defendant was a passenger?
- Was the stop justified under the community caretaking exception to the Fourth Amendment?
Disposition
- The Court of Appeals reversed the district court's denial of the motion to suppress and remanded the case with instructions to grant the motion to suppress (para 18).
Reasons
Per Vigil J. (Pickard and Wechsler JJ. concurring):
The Court held that the officers lacked reasonable suspicion to stop the vehicle. Reasonable suspicion requires specific, articulable facts indicating criminal activity, which were absent in this case. The officers' observations of the truck passing the accident scene twice and the passenger's "rubbernecking" were insufficient to establish suspicion of wrongdoing. The Court distinguished this case from others where repeated passes near a crime scene occurred under more suspicious circumstances (paras 7-14).
The Court also rejected the State's argument that the stop was justified under the community caretaking exception. The officers did not testify to any specific safety concerns about the Defendant or the vehicle occupants, and the exception could not be extended to justify the stop in this context (paras 15-17).
As the stop was an unlawful seizure under the Fourth Amendment, all evidence obtained as a result of the stop was inadmissible (para 18).