Peter Ickes

State v. Crawford, 659 N.W.2d 537 (Iowa 2003).

Facts
Police were responding to a potential domestic violence incident when they received word that
the alleged aggressor had left the home in a flatbed truck. The police officer came upon a flatbed
truck and pulled it over. While the passenger in the truck was the alleged aggressor, the driver
was unknown to the officer. The driver was eventually arrested, charged, and convicted for
operating while intoxicated. The defendant moved to suppress any evidence resulting from the
stop on the grounds that the stop was unconstitutional under the Fourth Amendment.

Issue
Whether the otherwise unconstitutional stop of the flatbed falls under the community-caretaking-
function exception.

Test
In a community caretaker (CC) case, the court should “balance the public need and interest
furthered by the police conduct against the degree and nature of the intrusion upon the privacy of
the citizen” to determine whether the exception applies.

Analysis
The CC exception requires 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 of privacy of the
citizen.” In evaluating whether an emergency existed, the court must determine “whether the
facts available to the officer at the moment of the seizure would have warranted a reasonable
person to believe an emergency existed.” Keep in mind, also, that the ultimate question is
“whether the search and seizure were reasonable in the light of the facts and circumstances of the
case.”

Applying the analysis, (1) the stop of the flatbed qualifies as a seizure within the meaning of the
Fourth Amendment, even though it was brief and for a limited purpose. Regarding (2), the
officer knew that the alleged aggressor had taken “some pills,” was agitated and physically
aggressive, and confused. He came upon a truck matching the description he was given, which
could be reasonably thought to contain the alleged aggressor. Finally, addressing (3), Even
though he did not know who was driving the truck and that the driver was intoxicated, the officer
was warranted in making the stop in the interest of public safety and emergency aid.

Holding
Ruling of the district court denying the motion to suppress is affirmed.