It’s common knowledge that police officers are not able to search for evidence of criminal activity without a warrant. The Fourth Amendment outlines this limitation in order to protect the rights of citizens. However, there are exceptions to this limitation, one of which is the community caretaking doctrine.
What is Community Caretaking?
Police officers are judged as acting within the capacity of community caretaking when their actions are “totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.” This allows them to check on individuals who may require aid or who, alternatively, may pose a risk to other community members.
In the case of Commonwealth vs. Sargsyan, police were called regarding a car that was parked on a dead-end street for what was judged to be an extended period of time. Officer Bergdorf arrived and found the car and its lights on, with a single occupant asleep in the driver’s seat.
The Details of Commonwealth vs. Sargsyan
The officer knocked on the window to wake the occupant, who became the defendant in this case. The defendant attempted to dismiss the officer and indicate that he did not need assistance by waving him away. For the sake of “officer safety,” Officer Bergdorf persisted by asking the defendant to provide his license and registration. The defendant struggled to engage with the officer, appearing groggy and disoriented. He at first provided credit cards rather than his license, and when he bent over to retrieve his registration, the officer noticed a knife in the waistband of the defendant’s pants.
The officer instructed the defendant to exit the vehicle, at which point he was handcuffed and patted down. When the defendant arose from his seat, previously obscured drug paraphernalia became visible to the officer. The defendant was subsequently read his rights and arrested.
The Defense
The defendant argued that when he waved the officer away, he indicated he didn’t require assistance, which rendered the officer’s community caretaking duties fulfilled. The defense was that the officer exceeded the bounds of his role as a community caretaker when he instructed the defendant to provide his license and registration and that everything that transpired from that point on qualified as a seizure.
The Prosecution
The counterargument provided by the prosecution was that the officer had a responsibility to ensure that Sargsyan was able to safely operate the vehicle, as a driver under the influence of drugs would pose a risk to the safety of other community members. Ultimately, the court ruled in favor of the prosecution, finding that the officer never stepped outside his community caretaking function, meaning no seizure occurred. The defendant was found guilty of Possession of a Class A substance and not guilty of Operating a Motor Vehicle While Under the Influence of a Narcotic Drug.
Why This Matters
The ruling in the matter of Commonwealth vs. Sargsyan has larger implications for the scope of community caretaking in the state of Massachusetts, potentially setting a precedent that could allow for the expansion of the police’s community caretaking powers.
If you find yourself in a situation like the defendant in Commonwealth vs. Sargsyan, be sure to contact an attorney immediately.
