community caretaking exception in Iowa

2023“Under the emergency aid doctrine, the officer has an immediate, reasonable belief that a serious, dangerous event is occurring.” Id. (quoting State v. Tyler, 867 N.W.2d 136, 170 (Iowa 2015)).3 “The community caretaking exception to the warrant requirement . . . is ‘totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.’ ” Id. (quoting Cady v. Dombrowski, 413 U.S. 433, 441 (1973)).

2023While the Supreme Court first recognized the community caretaking exception in Cady v. Dombrowski, which involved the search of an impounded vehicle for a firearm, see 413 U.S. at 437 , the community caretaking exception is also applicable to warrantless entries and searches of the home.

2023See Caniglia, 141 S. Ct. at 1605 (Kavanaugh, J., concurring).) In State v. Coffman, we applied a three-step inquiry to determine whether police could rely on the community caretaking exception. 914 N.W.2d at 245 .

2023“Under the emergency aid doctrine, the officer has an immediate, reasonable belief that a serious, dangerous event is occurring.” Id. (quoting State v. Tyler, 867 N.W.2d 136, 170 (Iowa 2015)).3 “The community caretaking exception to the warrant requirement . . . is ‘totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.’ ” Id. (quoting Cady v. Dombrowski, 413 U.S. 433, 441 (1973)).

2020To determine whether the community-caretaking exception applies, we “require a three-step analysis: (1) was there a seizure within the meaning of the Fourth Amendment?; (2) if so, was the police conduct bona fide community caretaker activity?; and (3) if so, did the public need and interest outweigh the intrusion upon the privacy of the citizen?” Crawford, 659 N.W.2d at 543 .

2020See, e.g., State v. Coffman, 914 N.W.2d 240, 254 (Iowa 2018) (discussing the community-caretaking exception under article I, section 8). “[T]he community caretaking exception encompasses three separate doctrines: (1) the emergency aid doctrine, (2) the automobile impoundment/inventory doctrine, and (3) the ‘public servant’ exception noted in Cady.” Crawford, 659 N.W.2d at 541 .

2015“A core notion of the community caretaking exception is that . . . it is ‘totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.’ ” Id. (quoting Cady v. Dombrowski, 413 U.S. 433, 441 , 93 S. Ct. 2523, 2528 , 37 L.

2015“A core notion of the community caretaking exception is that ... it is ‘totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.’ ” Id. (quoting Cady v. Dombrowski, 413 U.S. 433, 441 , 93 S.Ct. 2523, 2528 , 37 L.Ed.2d 706, 715 (1973)). “ ‘The community earetaking function involves the duty of police officers to help citizens an officer reasonably believes may be in need of assistance.’” Id. at 172-73 (quoting State v. Mireles, 133 Idaho 690 , 991 P.2d 878, 880 (Ct.App.1999)).

2016See State v. Crawford, 659 N.W.2d 537, 543 (Iowa 19 2003) (setting forth the elements of this exception); State v. Carlson, 548 N.W.2d 138 , 140–41 (Iowa 1996) (considering police officers’ entry into a home under the community caretaking exception).

2016See State v. Crawford, 659 N.W.2d 537, 543 (Iowa 19 2003) (setting forth the elements of this exception); State v. Carlson, 548 N.W.2d 138 , 140–41 (Iowa 1996) (considering police officers’ entry into a home under the community caretaking exception).

2018The community caretaking exception has three branches: "(1) the emergency aid doctrine, (2) the automobile impoundment/inventory doctrine, and (3) the 'public servant' exception." Tyler , 867 N.W.2d at 170 (quoting Kurth , 813 N.W.2d at 274 ).

2018In applying the Fourth Amendment, we have said that "the relevant test for determining whether the community caretaking exception applies is an objective one based on the information available at the time of the stop and does not depend upon the subjective motivations of the individual officers involved." Kurth , 813 N.W.2d at 279 n.3.

2023See Caniglia, 141 S. Ct. at 1605 (Kavanaugh, J., concurring).) In State v. Coffman, we applied a three-step inquiry to determine whether police could rely on the community caretaking exception. 914 N.W.2d at 245 .

2022But, while Caniglia reiterated that the community caretaking exception has a narrow scope that applies to vehicles in public places, it also recognized “that law enforcement officers may enter private property without a warrant when certain exigent circumstances exist, including the need to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.” 141 S. Ct. at 1599 (cleaned up) (quoting Kentucky v. King, 563 U.S. 452, 460, 470 (2011)); see also Brigham City v. Stuart, 547 U.S. 398, 403 (2006) (“Accordingly, law enforcement officers may enter a home wi

2021“Our 14Iowa Code section 804.7 lists six situations in which a peace officer may make an arrest without a warrant while Iowa Code section 804.9, which governs arrests by private persons, only lists two situations in which a private person may make an arrest. 15See Iowa Code § 804.15 . 16See Iowa Code § 805.1 (1). 17See Iowa Code § 804.11 (1). 18See Iowa Code § 704.11 (1). 19See State v. Tyler, 830 N.W.2d 288 , 292–93 (Iowa 2013) (discussing the validity of investigatory or Terry stops in the traffic stop context). 20SeeState v. Hilleshiem, 291 N.W.2d 314, 318 (Iowa 1980) (en banc) (explaining

2021“Our 14Iowa Code section 804.7 lists six situations in which a peace officer may make an arrest without a warrant while Iowa Code section 804.9, which governs arrests by private persons, only lists two situations in which a private person may make an arrest. 15See Iowa Code § 804.15 . 16See Iowa Code § 805.1 (1). 17See Iowa Code § 804.11 (1). 18See Iowa Code § 704.11 (1). 19See State v. Tyler, 830 N.W.2d 288 , 292–93 (Iowa 2013) (discussing the validity of investigatory or Terry stops in the traffic stop context). 20SeeState v. Hilleshiem, 291 N.W.2d 314, 318 (Iowa 1980) (en banc) (explaining

2015“A core notion of the community caretaking exception is that ... it is ‘totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.’ ” Id. (quoting Cady v. Dombrowski, 413 U.S. 433, 441 , 93 S.Ct. 2523, 2528 , 37 L.Ed.2d 706, 715 (1973)). “ ‘The community earetaking function involves the duty of police officers to help citizens an officer reasonably believes may be in need of assistance.’” Id. at 172-73 (quoting State v. Mireles, 133 Idaho 690 , 991 P.2d 878, 880 (Ct.App.1999)).

2015“A core notion of the community caretaking exception is that ... it is ‘totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.’ ” Id. (quoting Cady v. Dombrowski, 413 U.S. 433, 441 , 93 S.Ct. 2523, 2528 , 37 L.Ed.2d 706, 715 (1973)). “ ‘The community earetaking function involves the duty of police officers to help citizens an officer reasonably believes may be in need of assistance.’” Id. at 172-73 (quoting State v. Mireles, 133 Idaho 690 , 991 P.2d 878, 880 (Ct.App.1999)).

2023“Under the emergency aid doctrine, the officer has an immediate, reasonable belief that a serious, dangerous event is occurring.” Id. (quoting State v. Tyler, 867 N.W.2d 136, 170 (Iowa 2015)).3 “The community caretaking exception to the warrant requirement . . . is ‘totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.’ ” Id. (quoting Cady v. Dombrowski, 413 U.S. 433, 441 (1973)).

2023“Under the emergency aid doctrine, the officer has an immediate, reasonable belief that a serious, dangerous event is occurring.” Id. (quoting State v. Tyler, 867 N.W.2d 136, 170 (Iowa 2015)).3 “The community caretaking exception to the warrant requirement . . . is ‘totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.’ ” Id. (quoting Cady v. Dombrowski, 413 U.S. 433, 441 (1973)).

2021“Our 14Iowa Code section 804.7 lists six situations in which a peace officer may make an arrest without a warrant while Iowa Code section 804.9, which governs arrests by private persons, only lists two situations in which a private person may make an arrest. 15See Iowa Code § 804.15 . 16See Iowa Code § 805.1 (1). 17See Iowa Code § 804.11 (1). 18See Iowa Code § 704.11 (1). 19See State v. Tyler, 830 N.W.2d 288 , 292–93 (Iowa 2013) (discussing the validity of investigatory or Terry stops in the traffic stop context). 20SeeState v. Hilleshiem, 291 N.W.2d 314, 318 (Iowa 1980) (en banc) (explaining

2021“Our 14Iowa Code section 804.7 lists six situations in which a peace officer may make an arrest without a warrant while Iowa Code section 804.9, which governs arrests by private persons, only lists two situations in which a private person may make an arrest. 15See Iowa Code § 804.15 . 16See Iowa Code § 805.1 (1). 17See Iowa Code § 804.11 (1). 18See Iowa Code § 704.11 (1). 19See State v. Tyler, 830 N.W.2d 288 , 292–93 (Iowa 2013) (discussing the validity of investigatory or Terry stops in the traffic stop context). 20SeeState v. Hilleshiem, 291 N.W.2d 314, 318 (Iowa 1980) (en banc) (explaining

2021“Our 14Iowa Code section 804.7 lists six situations in which a peace officer may make an arrest without a warrant while Iowa Code section 804.9, which governs arrests by private persons, only lists two situations in which a private person may make an arrest. 15See Iowa Code § 804.15 . 16See Iowa Code § 805.1 (1). 17See Iowa Code § 804.11 (1). 18See Iowa Code § 704.11 (1). 19See State v. Tyler, 830 N.W.2d 288 , 292–93 (Iowa 2013) (discussing the validity of investigatory or Terry stops in the traffic stop context). 20SeeState v. Hilleshiem, 291 N.W.2d 314, 318 (Iowa 1980) (en banc) (explaining

2021“Our 14Iowa Code section 804.7 lists six situations in which a peace officer may make an arrest without a warrant while Iowa Code section 804.9, which governs arrests by private persons, only lists two situations in which a private person may make an arrest. 15See Iowa Code § 804.15 . 16See Iowa Code § 805.1 (1). 17See Iowa Code § 804.11 (1). 18See Iowa Code § 704.11 (1). 19See State v. Tyler, 830 N.W.2d 288 , 292–93 (Iowa 2013) (discussing the validity of investigatory or Terry stops in the traffic stop context). 20SeeState v. Hilleshiem, 291 N.W.2d 314, 318 (Iowa 1980) (en banc) (explaining

2026Under the Fourth Amendment, this exception permits an officer to “enter a home without a warrant if [the officer] has ʻan objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury.’” Case v. Montana, 607 U.S. __ , __, 146 S. Ct. 500 , 508 (2026) (quoting Brigham City v. Stuart, 547 U.S. 398, 400 (2006)).

2022But, while Caniglia reiterated that the community caretaking exception has a narrow scope that applies to vehicles in public places, it also recognized “that law enforcement officers may enter private property without a warrant when certain exigent circumstances exist, including the need to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.” 141 S. Ct. at 1599 (cleaned up) (quoting Kentucky v. King, 563 U.S. 452, 460, 470 (2011)); see also Brigham City v. Stuart, 547 U.S. 398, 403 (2006) (“Accordingly, law enforcement officers may enter a home wi

2020See State v. Kern, 831 N.W2d 149, 173–74 (Iowa 2013) (“The caretaking by the police in accompanying the DHS officer to Kern’s home ended when the DHS officer and the police officers removed the children from the home.”); see also United States v. Quezada, 448 F.3d 1005, 1008 (8th Cir. 2006) (concluding that an officer’s entry into a home fell under the community-caretaking exception because the officer’s observations of an entry door that easily pushed open, the television on, and no answer to officer’s inquires supported reasonable belief someone might be inside requiring aid).

2018See United States v. Quezada , 448 F.3d 1005 , 1007 (8th Cir. 2006) ; cf. Ray v. Twp. of Warren , 626 F.3d 170 , 177 (3d Cir. 2010) (holding, in the context of qualified immunity, that searching the home under community caretaking did not violate clearly established law); Phillips v. Peddle , 7 F. App'x 175 , 179-80 (4th Cir. 2001) (same).

2019Under Franks v. Delaware , 438 U.S. 154 , 155-56, 98 S. Ct. 2674 , 2676, 57 L.Ed.2d 667 (1978), police officers commit a constitutional violation if they knowingly or "with reckless disregard for the truth" falsely support a warrant application.

2019Under Franks v. Delaware , 438 U.S. 154 , 155-56, 98 S. Ct. 2674 , 2676, 57 L.Ed.2d 667 (1978), police officers commit a constitutional violation if they knowingly or "with reckless disregard for the truth" falsely support a warrant application.

2017See Commonwealth v. Evans, 764 N.E.2d 841, 844 (Mass. 2002). 8 Here, Coffman asserts he did not require any assistance from Deputy Hochberger, and therefore, the community-caretaking doctrine should not apply to this kind of seizure.

2017App. Ct. 2004) (holding community-caretaking exception justified officer stopping behind a car in the early morning hours with its brake lights engaged); Evans, 764 N.E.2d at 844 (holding the community-caretaking exception applied when an officer stopped a car pulled over in the breakdown lane late at night with its right blinker flashing).

2018For instance, in Winters v. Adams, the United States Court of Appeals for the Eighth Circuit found that a seizure of a driver in a parked vehicle was justified by the community caretaking doctrine. 254 F.3d 758, 764 (8th Cir. 2001). 2 There, the officers were responding to a complaint regarding an unknown, intoxicated individual.

2018For instance, in Winters v. Adams , the United States Court of Appeals for the Eighth Circuit found that a seizure of a driver in a parked vehicle was justified by the community caretaking doctrine. 254 F.3d 758 , 764 (8th Cir. 2001). 2 There, the officers were responding to a complaint regarding an unknown, intoxicated individual.

2018The Tennessee Supreme Court confronted a similar situation in State v. McCormick and found the seizure was justified by the community caretaking doctrine under the United States and Tennessee Constitutions. 494 S.W.3d 673, 689 (Tenn. 2016).

2018The Tennessee Supreme Court confronted a similar situation in State v. McCormick and found the seizure was justified by the community caretaking doctrine under the United States and Tennessee Constitutions. 494 S.W.3d 673 , 689 (Tenn. 2016).

2016See, e.g., State v. Kersh, 313 N.W.2d 566 , 568–69 (Iowa 1981) abrogated on other grounds by State v. Lake, 476 N.W.2d 55, 56 (Iowa 1991) (finding the officer acted reasonably in opening a car door to check on the driver’s condition after seeing a car parked oddly and finding the driver “slumped behind the wheel” and unconscious); State v. Ivankovic, No. 15-0622, 2016 WL 3269627 , at *3–5 (Iowa Ct. App. June 15, 2016) (finding an officer’s nighttime investigation of a parked running car occupied by an unconscious individual in the driver’s seat was a valid community caretaking encounter); Stat

2013See, e.g., State v. Carlson, 548 N.W.2d 138, 142-43 (Iowa 1996) (holding entry into a home to search for a missing person, after the person’s boyfriend gave conflicting information about the missing person’s whereabouts, was reasonable under the emergency aid exception); State v. Kersh, 313 N.W.2d 566, 568-69 (Iowa 1981) (holding that officer was justified in opening a car door to check on the condition of the defendant, who was slumped over the wheel), abrogated on other grounds by State v. Lake, 476 N.W.2d 55, 56 (Iowa 1991).

2016See, e.g., State v. Kersh, 313 N.W.2d 566 , 568–69 (Iowa 1981) abrogated on other grounds by State v. Lake, 476 N.W.2d 55, 56 (Iowa 1991) (finding the officer acted reasonably in opening a car door to check on the driver’s condition after seeing a car parked oddly and finding the driver “slumped behind the wheel” and unconscious); State v. Ivankovic, No. 15-0622, 2016 WL 3269627 , at *3–5 (Iowa Ct. App. June 15, 2016) (finding an officer’s nighttime investigation of a parked running car occupied by an unconscious individual in the driver’s seat was a valid community caretaking encounter); Stat

2013See, e.g., State v. Carlson, 548 N.W.2d 138, 142-43 (Iowa 1996) (holding entry into a home to search for a missing person, after the person’s boyfriend gave conflicting information about the missing person’s whereabouts, was reasonable under the emergency aid exception); State v. Kersh, 313 N.W.2d 566, 568-69 (Iowa 1981) (holding that officer was justified in opening a car door to check on the condition of the defendant, who was slumped over the wheel), abrogated on other grounds by State v. Lake, 476 N.W.2d 55, 56 (Iowa 1991).

2014See Kern, 831 N.W.2d at 172–73 (explaining the community-caretaking exception); State v. Watts, 801 N.W.2d 845, 850 (Iowa 2011) (mentioning four exceptions to the warrant requirement); State v. Naujoks, 637 N.W.2d 101, 107 (Iowa 2001) (listing four “well-recognized exceptions to the warrant requirement”).

2014See Kern, 831 N.W.2d at 172–73 (explaining the community-caretaking exception); State v. Watts, 801 N.W.2d 845, 850 (Iowa 2011) (mentioning four exceptions to the warrant requirement); State v. Naujoks, 637 N.W.2d 101, 107 (Iowa 2001) (listing four “well-recognized exceptions to the warrant requirement”).

2014See Kern, 831 N.W.2d at 172–73 (explaining the community-caretaking exception); State v. Watts, 801 N.W.2d 845, 850 (Iowa 2011) (mentioning four exceptions to the warrant requirement); State v. Naujoks, 637 N.W.2d 101, 107 (Iowa 2001) (listing four “well-recognized exceptions to the warrant requirement”).

2014See Kern, 831 N.W.2d at 172–73 (explaining the community-caretaking exception); State v. Watts, 801 N.W.2d 845, 850 (Iowa 2011) (mentioning four exceptions to the warrant requirement); State v. Naujoks, 637 N.W.2d 101, 107 (Iowa 2001) (listing four “well-recognized exceptions to the warrant requirement”).

2018In Kozak v. Commissioner of Public Safety, a Minnesota appellate court decided that a deputy’s conduct was justified under the community caretaking exception. 359 N.W.2d 625, 628 (Minn. Ct. App. 1984).

2018In Kozak v. Commissioner of Public Safety , a Minnesota appellate court decided that a deputy's conduct was justified under the community caretaking exception. 359 N.W.2d 625 , 628 (Minn. Ct. App. 1984).

2018In People v. Laake , the Illinois Appellate Court upheld a vehicle seizure under the community caretaking doctrine of the Fourth Amendment. 348 Ill.App.3d 346 , 284 Ill.Dec. 203 , 809 N.E.2d 769 , 772-73 (2004). 1 There, the officer received a report at approximately 3:00 a.m. from police dispatch about a possible intoxicated driver in his area of patrol.

2018In People v. Laake , the Illinois Appellate Court upheld a vehicle seizure under the community caretaking doctrine of the Fourth Amendment. 348 Ill.App.3d 346 , 284 Ill.Dec. 203 , 809 N.E.2d 769 , 772-73 (2004). 1 There, the officer received a report at approximately 3:00 a.m. from police dispatch about a possible intoxicated driver in his area of patrol.

2012Compare United States v. Gross, 662 F.3d 393, 396, 401 (6th Cir.2011) (holding that the community caretaking exception did not justify an officer’s decision to park his squad car directly behind a legally parked vehicle and activate his spotlights when that car was in the parking lot of a housing complex, with the engine running, no apparent driver, and a barely-visible individual slumped down in the passenger seat, and further noting that “any purported community-caretaking function in this instance could have been accomplished through a consensual encounter rather than an investigative stop”

2012Compare United States v. Gross, 662 F.3d 393, 396, 401 (6th Cir. 2011) (holding that the community caretaking exception did not justify an officer’s decision to park his squad car directly behind a legally parked vehicle and activate his spotlights when that car was in the parking lot of a housing complex, with the engine running, no apparent driver, and a barely-visible individual slumped down in the passenger seat, and further noting that “any purported community-caretaking function in this instance could have been accomplished through a consensual encounter rather than an investigative stop

2026State v. Bradford, 620 N.W.2d 503, 506 (Iowa 2000). 3 Deaton contends the district court erred by denying his motion to suppress based on the community caretaking exception to the warrant requirement.

2023In State v. Smith, police received a report of a single-car crash into a ditch at 4:30 a.m., but found no sign of the driver or any indications of injury. 919 N.W.2d 1, 2 (Iowa 2018) (per curiam).

2022But, while Caniglia reiterated that the community caretaking exception has a narrow scope that applies to vehicles in public places, it also recognized “that law enforcement officers may enter private property without a warrant when certain exigent circumstances exist, including the need to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.” 141 S. Ct. at 1599 (cleaned up) (quoting Kentucky v. King, 563 U.S. 452, 460, 470 (2011)); see also Brigham City v. Stuart, 547 U.S. 398, 403 (2006) (“Accordingly, law enforcement officers may enter a home wi

2022But, while Caniglia reiterated that the community caretaking exception has a narrow scope that applies to vehicles in public places, it also recognized “that law enforcement officers may enter private property without a warrant when certain exigent circumstances exist, including the need to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.” 141 S. Ct. at 1599 (cleaned up) (quoting Kentucky v. King, 563 U.S. 452, 460, 470 (2011)); see also Brigham City v. Stuart, 547 U.S. 398, 403 (2006) (“Accordingly, law enforcement officers may enter a home wi