State v. Anderson, 2015 UT 90 (Oct. 28, 2015)

The criminal defendant appealed the denial of a motion to suppress following conviction by a jury. The Utah Supreme Court held that the defendant was seized when the police pulled up and parked directly behind him on the side of the road with their lights activated, because a reasonable person would not have felt free to leave. It then evaluated whether the seizure was justified by the community caretaking doctrine. In doing so, it abandoned the court’s previous requirement that there be imminent danger to life or limb. The current test for application of the community caretaking doctrine requires courts to first evaluate the degree to which an officer intrudes upon a citizen’s freedom of movement and privacy and then determine whether the degree of the public interest and the exigency of the situation justified the seizure for community caretaking purposes.