Understanding the 4th Amendment: What Happened with the Abandoned Vehicle?

Alexander Hillel Treisman appeals the district court’s denial of his motion to suppress evidence that police discovered while searching his van without a warrant. But warrantless searches of vehicles carried out as part of law enforcement’s community caretaking functions do not violate the Fourth Amendment if they are reasonable under the circumstances. And because the record here supports the district court’s conclusion that the officers acted reasonably in searching the van under their community caretaking functions, we affirm.

The Supreme Court first mentioned this concept in Cady v. Dombrowski, 413 U.S. 433 (1973). There, the Court explained,

Some [contacts between citizens and police involving automobiles] will occur because the officer may believe the operator has violated a criminal statute, but many more will not be of that nature. Local police 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 ….
Id. at 441. Elaborating, the Court described community caretaking functions as conduct “totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.” Id. And it also clarified that the test for evaluating whether community caretaking searches violate the Fourth Amendment is reasonableness. Id. at 442. In other words, is the search reasonable given the totality of the circumstances?

Full case here: United States v. Treisman, No. 21-4687 (4th Cir. Jun. 23, 2023), https://casetext.com/case/united-states-v-treisman