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When two Garfield County sheriff's deputies saw a car parked on the side of a rural highway with its hazard lights flashing on a cold winter night, they flipped on the red and blue lights on their cruiser and pulled up behind the vehicle to check on the occupant's welfare.
Cameron Anderson, the man sitting behind the wheel, was fine but soon ended up in legal trouble: The deputies found drug paraphernalia and a small amount of marijuana in the car and based on that discovery, he was eventually convicted of two class A misdemeanors.
Anderson appealed his conviction, alleging the evidence against him should have been thrown out because it was obtained in violation of the Fourth Amendment prohibition against unreasonable searches and seizure.
But the Utah Supreme Court disagreed. In a 4-0 ruling handed down Wednesday, the high court concluded the deputies' actions were justified under the "community caretaking doctrine."
According to court documents, the deputies approached Anderson's car on Dec. 23, 2011, to ask if he needed assistance but became suspicious that he was driving under the influence when they noticed his eyes appeared bloodshot. In addition, Anderson, a Washington state resident, was not sure which direction he was traveling at the time.
Anderson declined to take a field sobriety test but agreed to a blood draw. No illegal substances were found in his blood but a search of the car — conducted after the deputies obtained a search warrant — turned up less than an ounce of marijuana and the drug paraphernalia, court records say.
A jury found Anderson guilty of the two misdemeanors and he was sentenced to 10 days in jail and 24 months of probation.
The Supreme Court ruling in the case centered on whether the deputies effected a seizure of Anderson by pulling up behind his car with lights flashing and if so, whether that seizure, which led to the discovery of the drug evidence, was justified.
Writing for the court, Justice Christine Durham said "yes" to both questions.
An officer's use of overhead lights behind a vehicle parked on the side of the road can constitute a seizure, Durham wrote. And although police might use their lights for safety reasons rather than as a command to stop, the average motorist would not necessarily feel free to drive away, she said.
In Anderson's case, the stop was a seizure within the meaning of the Fourth Amendment, according to the ruling, and was "a reasonable exercise of the deputies' community caretaking function" because of the circumstances.
The caretaking doctrine stems from a 1973 U.S. Supreme Court decision that recognized police often engage in activities to assist the public that have nothing to do with investigating a possible crime.
The Utah Supreme Court decision said a reasonable officer would have cause to be concerned about the welfare of a motorist in Anderson's situation and that the deputies detained him for community caretaking purposes only long enough to approach his car and ask whether he needed help.
Once the deputies became suspicious that Anderson was driving under the influence of an illegal substance, the nature of the detention switched from a caretaking stop to an investigatory detention, the ruling said.
Durham pointed out that it was just before 10 p.m., the temperature had dropped to about 7 below zero and Anderson was parked with his hazard lights flashing.
"Given the decent odds that a motorist in this situation may need help, an officer would have reason to be concerned and to at least stop to determine whether assistance is needed," Durham wrote.
Twitter: @PamelaMansonSLC