State of Tennessee v. Kenneth McCormick

We granted this appeal to reconsider our decision in State v. Moats, 403 S.W.3d 170 (Tenn. 2013), which held that the community caretaking doctrine is not an exception to the federal and state constitutional warrant requirements. Having concluded that Moats was wrongly decided, we overrule Moats and hold that the community caretaking doctrine is analytically distinct from consensual police-citizen encounters and is instead an exception to the state and federal constitutional warrant requirements which may be invoked to validate as reasonable a warrantless seizure of an automobile. To establish that the community caretaking exception applies, the State must show that (1) the officer possessed specific and articulable facts, which, viewed objectively and in the totality of the circumstances, reasonably warranted a conclusion that a community caretaking action was needed; and (2) the officer’s behavior and the scope of the intrusion were reasonably restrained and tailored to the community caretaking need. We conclude, based on the proof in the record on appeal, that the community caretaking exception applies in this case. Accordingly, the judgments of the trial court and Court of Criminal Appeals declining to grant the defendant’s motion to suppress are affirmed on the separate grounds stated herein.