Mayfield v. State (Unublished Memo): DWI case explains the distinction between two varieties of warrantless searches: exigent circumstances and community caretaker.
A concerned citizen observed Mayfield driving erratically through Tyler– swerving, running red lights, etc. The concerned citizen followed Mayfield to Mayfield’s home. The whole time the citizen was on the phone with Tyler PD, giving the plate number of Mayfield’s vehicle, a description of Mayfield’s vehicle, and a play-by-play of Mayfield’s actions. As Tyler PD was on its way, Mayfield came back out of his house and moved his vehicle from his driveway (where he’d first parked) into the garage. The garage door was open when the officer arrived. The officer could see Mayfield slumped over the wheel with one leg hanging out the open driver’s door. Without getting a warrant, the officer entered Mayfield’s garage and roused him. It was obvious that Mayfield was drunk, and the officer arrested him. Mayfield contends the arrest resulted from a warrantless search.
Warrantless searches are presumed invalid, but there are exceptions.
One category of exceptions is “exigent circumstances.” There must be probable cause, plus a good reason why there wasn’t time to actually get a warrant.
Another category of exceptions is “community caretaker.” Probable cause isn’t needed for community caretaker searches. The community caretaker doctrine allows the use of evidence discovered when officers are performing non-criminal duties, such as rendering emergency aid to people in distress. If the officer’s motivation was primarily criminal investigation, the community caretaker exception doesn’t apply.
In this case, the community caretaker exception doesn’t apply because of the officer’s criminal investigation motive.
Even so, the search is valid because of the exigent circumstances exception. The probable cause was supplied by the concerned citizen’s detailed, first-hand account of events. That, and the fact that a guy slumped over the wheel could be passed-out drunk. What’s more, the sight of a guy slumped over the wheel in his garage counts on the “reason why there wasn’t time to get a warrant” side of the ledger, too. Confronted with that situation, an officer has good reason not to stand around waiting for a warrant. Though the guy’s probably drunk, the officer can’t rule out heart attack or stroke until he goes into the garage. And if the guy behind the wheel is just drunk, there’s a chance he’d come to and take off back onto the public streets if the officer waited around for a warrant. So the search was valid, and the conviction was affirmed.
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