Wood v. Commonwealth

BENTON, Judge,

dissenting.

Because I believe that the warrantless entry by the police into the second floor of Wood’s residence was not justified by any “community caretaking” function, I would reverse the decision of the trial judge denying the motion to suppress. Therefore, I dissent.

*664I.

“The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.... ” U.S. Const, amend. IV. “The Fourth Amendment protects the individual’s privacy in a variety of settings. In none is the zone of privacy more clearly defined than when bounded by the unambiguous physical dimensions of an individual’s home.... ” Payton v. New York, 445 U.S. 573, 589, 100 S.Ct. 1371, 1381-82, 63 L.Ed.2d 639 (1980). Well settled is the “ ‘basic principle of Fourth Amendment law5 that searches ... inside a home without a warrant are presumptively unreasonable.” Id. at 586, 100 S.Ct. at 1380 (citation omitted).

Noting that the United States Supreme Court, in Cady v. Dombrowski, 413 U.S. 433, 439-42, 93 S.Ct. 2523, 2527-29, 37 L.Ed.2d 706 (1973), “discussed well-established privacy distinctions between automobiles and residences in affirming the reasonableness of the [automobile] search in that case,” the majority nevertheless ignores these distinctions. In Cady, the Supreme Court stated:

Because of the extensive regulation of motor vehicles and traffic, and also because of the frequency with which a vehicle can become disabled or involved in an accident on public highways, the extent of police-citizen contact involving automobiles will be substantially greater than police-citizen contact in a home or office. Some such contacts will occur because the officer may believe the operator has violated a criminal statute, but many more will not be of that nature. Local police officers, unlike federal officers, frequently investigate vehicle accidents in which there is no claim of criminal liability and engage in what, for want of a better term, may be described as community caretaking functions, totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.
... The constitutional difference between searches of and seizures from houses and similar structures and from vehi*665cles stems both from the ambulatory character of the latter and from the fact that extensive, and often noncriminal contact with automobiles will bring local officials in “plain view” of evidence, fruits, or instrumentalities of a crime, or contraband.

Id. at 441-42, 93 S.Ct. at 2528.

The Supreme Court’s emphasis on the distinction between vehicle searches and searches of an individual’s home strongly implies that the community caretaking function used to uphold the vehicle search in Cady would not justify an intrusion into an individual’s home. This inference was verified when the Court later stated, in South Dakota v. Opperman, 428 U.S. 364, 367, 96 S.Ct. 3092, 3096, 49 L.Ed.2d 1000 (1976), the following:

This Court has traditionally drawn a distinction between automobiles and homes or offices in relation to the Fourth Amendment. Although automobiles are “effects” and thus within the reach of the Fourth Amendment, Cady v. Dombrowski, 413 U.S. 433, 439 [93 S.Ct. 2523, 2527, 37 L.Ed.2d 706] (1973), warrantless examinations of automobiles have been upheld in circumstances in which a search of a home or office would not. Cardwell v. Lewis, 417 U.S. 583, 589 [94 S.Ct. 2464, 2468-2469, 41 L.Ed.2d 325] (1974); Cady v. Dombrowski, supra, at 439-440 [93 S.Ct. at 2527-2528]; Chambers v. Maroney, 399 U.S. 42, 48 [90 S.Ct. 1975, 1979-1980, 26 L.Ed.2d 419] (1970).

By citing Cady as an example of a search that would not have been upheld if it had involved an intrusion into an individual’s home, I believe the Court made clear that the community caretaker doctrine cannot be used to justify a warrantless intrusion into a home. Accordingly, I would hold that the trial judge erred in holding that the warrantless entry into the second floor of Wood’s residence was justified by the community caretaker doctrine.6

*666II.

Assuming arguendo that the community caretaking doctrine may under appropriate circumstances justify warrantless searches of residences, I disagree with the majority’s assertion that the search of the second floor of Wood’s home was a valid exercise of that function. In Cady, the Supreme Court described “community caretaking functions” as being “totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.” See Cady, 413 U.S. at 441, 93 S.Ct. at 2528. The evidence in this case proves that the search was not “totally divorced from” a criminal investigation-.

The undisputed evidence proved that, on the night of the search, Wood’s wife went to the police station and reported that Wood had assaulted her. The police promptly went to Wood’s residence to investigate the alleged assault. When the police arrived, they entered Wood’s house to discuss the assault, arrested Wood, and took Wood to the police station. Two officers remained at the house to wait for a social worker to take custody of Wood’s children. After the social worker left with the children, the officers searched the second floor attic.

Because the search was a direct result of Wood’s arrest, the search was not “totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.” Id. The officers entered the residence to conduct a criminal investigation and were still so employed when they began the search.

*667The majority suggests that the police officers went upstairs to search for a missing teenager. Although the officers testified that they knew Wood’s wife’s teenage son had been reported missing and that they were searching for the missing juvenile, the evidence belies that assertion. Officer Gholson testified that the Wood family had reported missing a juvenile “that lived at [Wood’s] residence.” Nevertheless, the officers stated that they were searching Wood’s residence for the missing juvenile. The explanation that they were searching for a missing child at that child’s own residence is dubious at best. The evidence also proved that after the officers arrested Wood and removed him from the residence at approximately midnight, the two officers who remained behind called a social worker. Two children were sleeping in the living room. While the two officers waited in the residence for the social worker to arrive, they did not look for the teenager. Only after the social worker left with the other children did they begin their search. The delay in conducting the search casts additional doubt on the officers’ assertion that they were merely looking for the juvenile. Moreover, even if they were searching the house to find a teenager who had been reported missing by the parents who resided in the house, the officers obviously were conducting a criminal investigation.

I disagree with the suggestion that the police officers were permitted to enter rooms of the house to avoid leaving anyone behind or to assure that the house was secure. The officers stated that the search was instigated, in part, by the fact that they saw a light on upstairs. The police were not privileged to explore other rooms in the residence merely because they saw a light on in a residence at night. They did not inquire of Wood or his wife about whether other people were in the residence and did not call aloud while in the residence to ascertain whether anyone else was present. They heard no noise to suggest another person was there. Moreover, if they truly were concerned about securing the residence, they would not have left the door to the residence unlocked, as they did, when they left the residence.

*668Because the evidence indicates that the search for the child was “a pretext concealing an investigatory police motive,” Opperman, 428 U.S. at 376, 96 S.Ct. at 3100, I would hold that the search was not a valid exercise of the community caretaking function.

For these reasons, I would hold that the trial judge erred in using the community caretaking function to admit the evidence and I would further hold that the evidence should have been suppressed. Accordingly, I dissent.

. I believe that the Supreme Court has also circumscribed searches under the community caretaker doctrine by requiring the search to be *666based upon a police department’s "standard procedure” designed to protect the public and the police from danger. Cady, 413 U.S. at 443, 93 S.Ct. at 2529; accord Opperman, 428 U.S. at 369, 374-75, 96 S.Ct. at 3097, 3099-3100. Indeed, the Supreme Court of Virginia has noted that Cady and Opperman "involved the admissibility of incriminating evidence discovered during a standard police procedure of inventorying property that had properly been taken into custody.” Barrett v. Commonwealth, 250 Va. 243, 247, 462 S.E.2d 109, 111 (1995). None of those factors exists in this case.