Deciding that the “community caretaker role” exception to the Fourth Amendment can be extended beyond questions regarding seizures of a vehicle, the Indiana Court of Appeals affirmed a man’s cocaine conviction Monday after finding that evidence of the cocaine was not admitted in violation of his constitutional rights.
In August 2015, Indianapolis Metropolitan Police Department Officer Aaron Helton observed a man lying face-down and unresponsive on a sidewalk. When medics arrived at the scene, William McNeal approached Helton, who noticed that the man was sweating, had red eyes and slurred speech and had a rapid heartbeat that looked like his heart “was beating out of his chest.” When the man began to wake up, McNeal repeatedly told him “We got to go,” then began speaking gibberish.
McNeal continued to try to leave the scene but kept falling down, so Helton handcuffed him to keep him seated at the scene. The medics determined that both the unconscious man and McNeal needed to go to the hospital, but before McNeal was transported Helton ran a check on his identification and found that McNeal had an outstanding arrest warrant. A subsequent search incident to arrest also found three baggies of cocaine in his pants pocket.
The state charged McNeal with Level 5 felony possession of cocaine, but McNeal filed a motion to suppress, arguing that his detention by police was unconstitutional, so all evidence subsequently obtained was inadmissible. The Marion Superior Court denied the motion and McNeal was convicted after a bench trial.
McNeal appealed in William McNeal v. State of Indiana, 49A05-1604-CR-838, arguing that the trial court had abused its discretion by admitting the cocaine as evidence. Specifically, he argued that the evidence was obtained in violation of his constitutional protections in the Fourth Amendment of the U.S. Constitution and Article 1, Section 11 of the Indiana Constitution, both of which protected against unlawful searches and seizures.
But a panel of the Indiana Court of Appeals disagreed with both constitutional challenges Monday and affirmed McNeal’s cocaine conviction.
Judge Terry Crone, writing for the panel, said Helton’s detention of McNeal was reasonable under police officers’ community caretaking function.
Crone wrote that the panel, using a three-part community caretaking analysis, found that Helton had detained McNeal out of concern for his safety and health and, further, handcuffed him because it was the most feasible, effective and least intrusive way for Helton to secure McNeal’s safety.
“We emphasize that although prior Indiana courts have either not had occasion or not been inclined to extend the community caretaking exception beyond inventory searches of impounded vehicles, and most recently have extended the community caretaking function only to cases in which a vehicle is involved in some way… it would be illogical to think that a police officer cannot aid a citizen in distress, abate hazards, or perform the ‘infinite variety of other tasks calculated to enhance and maintain the safety of communities’ simply because a vehicle is not involved,” Crone wrote.
Additionally, because McNeal had voluntarily interrupted Helton and because he was speaking in gibberish and continually falling, the panel found that a reasonable person could conclude that McNeal had or was going to commit the crime of public intoxication.
Finally, Crone wrote that under the totality of the circumstances, Helton’s detention of McNeal was reasonable and, thus, was not in violation of his rights under Article I Section 11 of the Indiana Constitution.