State v. Anderson

ZIMMERMAN, Chief Justice,

concurring in the result:

As a preliminary matter, and on behalf of Justices Stewart and Durham, I must point out that the lead opinion’s directive to Utah courts to construe article I, section 14 of the Utah Constitution in a manner similar to constructions of the Fourth Amendment except in compelling circumstances is not supported by a majority of this court and is not Utah law.

Turning to the merits, I agree with the lead opinion’s conclusion that Anderson’s arrest and the two subsequent searches of his vehicle did not violate constitutional or statutory mandates. I write separately, however, to elaborate on Justice Durham’s criticism of the lead opinion’s methodology in reaching its result, criticism with which I strongly agree.

In its discussion of the roadside search of Anderson’s automobile, the lead opinion needlessly reexamines federal precedent since our plurality opinion in State v. Lancco, 794 P.2d 460 (Utah 1990). The rule endorsed in Lanceo — that a warrantless automobile search must be premised on probable cause and exigent circumstances — is identical to the rule “newly found” by the lead opinion and applied in the instant case. If anything, that sequence of events supports what the lead opinion purports to attack, namely, the beneficial effect of undertaking an independent analysis of Utah constitutional language. Simply put, the plurality’s willingness in Lar-occo to independently analyze the Utah Constitution prevented the confusion surrounding the automobile warrant exception that existed in federal courts from proliferating here in Utah. The fact that the United States Supreme Court subsequently reached the same rule as articulated in Lanceo in no way merits abandoning an independent state constitutional analysis on the ground that it is not necessary except in “the most compelling circumstances.” Our prior cases do not establish such a rule.

As to the lead opinion’s extension of the automobile warrant exception to the search of Anderson’s car at the station house, I agree that Lanceo is not controlling because in Lanceo, there was no evidence that the police acted under exigent circumstances at any time. I do, however, fault the lead opinion for blindly adhering to federal precedent on this issue without even articulating the policy reasons for its holding that exigent circumstances need exist only at the initial seizure of the automobile. Particularly in an area such as search and seizure law where, frequently, “the facts to which the legal rule is to be applied are so complex and varying,” State v. Pena, 869 P.2d 932, 939 (Utah 1994), an articulation of the policy bases for a new rule imposed on our trial courts is crucial so that they have some guidance in how to apply it when confronted -with slightly different facts than those of the present ease. The lead opinion’s omission is precisely traceable to its failure to “do the work,” as Justice Durham writes. I therefore agree with her on the meaning of Utah’s article I, section 14 and dissent from any implication in the lead opinion that this court must follow in lockstep with whatever the United States Supreme Court finds in the similarly worded Fourth Amendment.