Summary
The Rhode Island Supreme Court affirmed Louise Roussell’s conviction for operating a vehicle under the influence of alcohol. The court held that a state trooper reasonably opened the passenger-side door of her vehicle under the community-caretaking doctrine after she abruptly stopped near the trooper’s cruiser in the breakdown lane. The court therefore upheld the denial of her motion to suppress the field-sobriety and Breathalyzer results.
Topics
Practice areas
Questions Presented
- Whether the trooper's opening of defendant's passenger-side car door violated the Fourth Amendment or applicable state constitutional protections against unreasonable searches and seizures.
- Whether the field-sobriety and Breathalyzer results were fruits of an unlawful search and therefore should have been suppressed.
Holdings
- The trooper acted reasonably under the community-caretaking doctrine when he opened the passenger-side door and asked defendant what was the matter; the circumstances provided reasonable grounds to suspect that something was amiss and warranted further investigation for the safety of the officer, defendant, and other highway users.
- The Superior Court properly denied the motion to suppress because the trooper's opening of the car door did not violate the Fourth Amendment, and the challenged evidence was not obtained through an unlawful search.
Key quotations
“we hold that the trooper had reasonable grounds to suspect that something was sufficiently amiss to warrant further investigation and inquiry, not only to protect his own safety, but also the safety of defendant and the other drivers on this highway.” (770 A.2d at 860)
“Having observed the defendant abruptly pull up her vehicle behind his marked cruiser after traveling in the breakdown lane, we hold that the trooper acted reasonably under the community-caretaking doctrine when he opened the defendant's passenger-side door and “asked her what was the matter.”” (770 A.2d at 861)
Factual background
A state trooper stopped a vehicle on Route 24 and activated his cruiser's emergency lights. He then saw defendant's automobile traveling in the breakdown lane at the same speed as traffic, without hazard lights, and abruptly stop approximately ten feet behind his cruiser, partly protruding into the travel lane. Because the circumstances suggested both a potential safety risk and that defendant might be in trouble, the trooper approached from the passenger side and opened the door, whereupon he observed an odor of alcohol, slurred speech, watery and bloodshot eyes, and difficulty standing. Defendant failed field-sobriety tests, was arrested, and voluntarily submitted to a Breathalyzer test at the police barracks.
Procedural history
A state trooper opened the passenger-side door of defendant's vehicle after she abruptly stopped near the rear of the trooper's marked cruiser while traveling in the breakdown lane. The trooper observed signs of intoxication, administered field-sobriety tests, and arrested defendant; she later voluntarily submitted to a Breathalyzer test. The Superior Court denied defendant's suppression motion, and a jury convicted her. The Rhode Island Supreme Court summarily decided the appeal after a single justice ordered defendant to show cause.