Cady v. Dombrowski – Case Brief Summary (U.S. Supreme Court)

In Cady v. Dombrowski, 413 U.S. 433 (1973), the defendant's car struck a bridge abutment. 413 U.S. at 435-36. The defendant-driver was taken to the hospital and was arrested on charges of DUI. Id. at 436-37.

Upon learning that the defendant was a Chicago policeman, and believing that he was required to have a weapon at all times, the officers returned to the car to retrieve the weapon from the vehicle and prevent "the possibility that a revolver would fall into untrained or perhaps malicious hands." Id. at 443.

In doing so, the police found evidence that linked the defendant to a murder.

In upholding the admissibility of the evidence against a Fourth Amendment challenge, the Court described what it referred to as the community caretaking function of police officers:

Local police officers . . . frequently . . . 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. Id. at 441.

In Cady v. Dombrowski, the Court stated that because motor vehicles and traffic are extensively regulated, and because vehicles may frequently become disabled or involved in accidents on public roads, "local police officers . . . frequently investigate vehicle accidents in which there is no claim of criminal liability and engage in what . . . 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." Id. at 441.

The Court emphasized that there is a "constitutional difference between searches of and seizures from houses and similar structures and from vehicles," which "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 442.

In Cady v. Dombrowski, a defendant police officer had a one-car accident while intoxicated. 413 U.S. at 435-36.

The officers investigating the crash had reason to believe that the defendant was required to carry his service revolver at all times, but could not find it in the passenger compartment of his car or on his person. Id. at 436.

While looking in the trunk for the service weapon, officers discovered various bloody items linking the defendant to a murder. Id.

The Court held that entering the trunk was not unreasonable because, as in this case, the officers' attempts to recover the weapon were reasonable to "protect the public from the possibility that a revolver would fall into untrained or perhaps malicious hands." Id. at 443.

The United States Supreme Court recognized that because of the extensive regulation of motor vehicles by states and localities and the frequency with which vehicles can become disabled or involved in an accident, local law enforcement may appropriately and lawfully engage in what the Court described as "community caretaking functions."

Such "police-citizen" contacts relating to public safety are "totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute." Id.

In Cady, after an accident, a Chicago police officer was arrested for drunken driving, later became comatose, and his vehicle was towed to a nearby garage.

Local police officers conducted a search of the trunk because they had reason to believe that it contained a service revolver belonging to the driver. Id. at 442-43.

The Supreme Court held that based on the community caretaking exception to the warrant requirement, the warrantless search of the trunk of the vehicle to retrieve the revolver was reasonable under the Fourth Amendment in order to protect "the general public who might be endangered if an intruder removed a revolver from the trunk of the vehicle" and it fell into improper hands. Id. at 447.

The United States Supreme Court in Cady v. Dombrowski, first described the broad array of noncriminal noninvestigative police duties as "community caretaking functions. "

In Cady, the Court noted: "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." Cady, 413 U.S. at 441.

The United States Supreme Court acknowledged that local police "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." Cady, 413 U.S. at 441.

In Cady, search disabled car suspected of containing gun permissible because car was "vulnerable to intrusion by vandals").

The court of criminal appeals distinguished the Cady doctrine from the closely related emergency community caretaking doctrine because the Cady doctrine:

(1) does not require an officer to be acting only to preserve or protect life or avoid serious injury;

(2) applies primarily to searches and seizures of vehicles.

In Cady, an intoxicated police officer was involved in a car accident in another jurisdiction and lapsed into a coma. 413 U.S. at 435-36.

Police towed his car to an unguarded private garage and later searched the car looking for the service revolver they believed the injured officer was required to carry; the searchers instead discovered evidence of a murder committed by the injured officer. Id. at 436-37.

The Supreme Court held that, where the trunk of an automobile reasonably believed to contain a gun was vulnerable to intrusion by vandals, the search was not unreasonable within the meaning of the Fourth and Fourteenth Amendments. Id. at 448.

In Cady the police were simply responding to a traffic accident. Id. at 436.

Because the defendant in Cady was an off-duty police officer thought to be carrying a service revolver, one of the responding officers looked in the front seat and glove compartment for the revolver at the scene of the accident.

Finding no revolver, the police then summoned a tow truck to remove the disabled vehicle.

A wrecker arrived and towed the vehicle to a privately owned garage. It was undisputed that the vehicle was no longer in police control after it was towed.

The defendant was arrested for drunken driving and, after questioning, taken to a hospital for unspecified injuries sustained in the accident. Id.

Several hours later, one of the officers drove to the private garage where the vehicle had been towed and searched it more thoroughly for the revolver.

Between the two front seats and in the trunk, the officer found evidence of a murder. Id. at 437.