State v. Burgess
In State v. Burgess, 163 Vt. 259, 657 A.2d 202 (1995), the Court held that the community caretaking doctrine did not apply where an officer approached a legally parked vehicle on the side of the road and inquired whether they needed assistance. 163 Vt. at 262, 657 A.2d at 204.
Burgess is clearly distinguishable from this case: whereas in Burgess "there was nothing . . . to indicate that defendant was in any type of distress," here the officer was signaled by the vehicle. Id.