Anderson v State

Anderson appealed his drug possession conviction arguing his motion to suppress should have been granted. The Court affirmed. It first held that a person can be seized for 4th Amendment purposes when an officer pulls behind a car on the side of a highway with the overhead lights activated because the lights communicate an ambiguous message at best and a reasonable person would not feel free to drive off. The Court noted in so deciding it was agreeing with the Utah Court of Appeals and the majority of state appellate courts which have decided the issue. It also noted the question of seizure is fact specific, but, on the facts here there was a seizure. It next held that the Utah standard for evaluating community caretaking  claims, that there be an imminent danger to life and limb,  has been undermined by more recent United States Supreme Court precedent allowing emergency entry for small cuts and the standard for searching cars should not be more stringent that the standard for entering a house. The Court adopted as the new standard a balancing test weighing the severity of the intrusion by officers against degree of public interest and severity of the emergency. Applying here, the court held that there was minimal intrusion into Anderson’s rights as he was already on the side of the highway and had his emergency lights on and the public interest was significant as it was night and very cold and a reasonable officer would perceive decent odds that occupants in the car might need assistance.