Community-Caretaking Doctrine Not Unlimited

In United States v. Morgan, the Sixth Circuit clarified the limits of the community-caretaking doctrine. 

On a winter morning, a police officer saw a man seemingly passed out at the wheel of his stopped but running car. Without investigating further or taking any action to rouse the driver, the officer opened the car door. This led to an altercation and Mr. Morgan was arrested for possession of a firearm and drugs. The district court denied his motion to suppress, finding the seizure justified by the community-caretaking exception. The Sixth Circuit reversed.

In doing so, the Court first discussed the history of police community service, running back to “watchman’s roles long before the dawn of the Republic.” Slip Opin. at 4. Ultimately however, the Court emphasized the limitations of the doctrine, finding that “[c]oncerns about the health of a driver by themselves generally do not permit the unannounced opening of a car door.” Id. at 6. There were “myriad, less intrusive paths available” to the officer to investigate any concerns about the driver, like activating his emergency lights, shining a flashlight at the driver, calling out to him, or knocking on the window. The Court emphasized that the intrusion must be reasonable, matching the actual problem.

The Court also dismissed the officer’s contention that he needed to open the car door suddenly to keep the driver from hitting the gas and causing harm, as suddenly opening the driver’s side door was more startling than any of the other less intrusive options. An officer must first, in some way, confirm that an actual exigency exists to rely on the community-caretaking exception.