NY: Community caretaking function justified stop of a moving vehicle but its continuation was unreasonable

NY evaluates the stop and continued seizure of a moving vehicle under the community caretaking function, and concludes this one continued past the need for the stop and was unreasonable. (The court notes a lot of state decisions on the question of stop of a moving vehicle.) People v. Brown, 2024 NY Slip Op 02765, 2024 NY Slip Op 02765 (May 21, 2024):

In light of our previous recognition that police officers are often called upon to provide “historically grounded, and usually welcome” aid to those in distress (see id. at 545), we, like many other state high courts, recognize a community caretaking doctrine that may allow police to stop a moving vehicle. We nevertheless acknowledge, as many of our sister courts have, the risk that the community caretaking doctrine may be used by police to circumvent the federal and state constitutional rights afforded to citizens to protect them from unreasonable and unwarranted police intrusions (see id. [care must be taken “not to allow this historically grounded, and usually welcome, explanation for police work to overrun core Fourth Amendment protections”]). The standard we adopt for community caretaking in this context must weigh both of those concerns.

We conclude that the police may stop an automobile in an exercise of their community caretaking function if two criteria exist. First, the officers must point to specific, objective, and articulable facts that would lead a reasonable officer to conclude that an occupant of the vehicle is in need of assistance. Second, the police intrusion must be narrowly tailored to address the perceived need for assistance. Once assistance has been provided and the peril mitigated, or the perceived need for assistance has been dispelled, any further police action must be justified under the Fourth Amendment and Article I, section 12 of the State Constitution.

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