State v. Oneill

Under the community caretaking exception to the warrant requirement, police may impound vehicles that impede traffic, jeopardize public safety, and are subject to vandalism or theft.

Defendant appealed his possession of methamphetamine conviction. A Clackamas County Deputy pulled over Defendant and decided to impound the vehicle pursuant to the Clackamas County Code after discovering the driver had a suspended license and was uninsured. Before towing, the Deputy searched the vehicle and found methamphetamine. At trial, Defendant moved to suppress the methamphetamine discovery, arguing that it violated his Fourth Amendment rights and did not come under the community caretaking exception to the warrant requirement. The trial court denied the motion, and Defendant was subsequently convicted. On appeal, Defendant argued that the lack of a public safety concern dissipated the community caretaking exception to the warrant requirement. The Court of Appeals noted that under the community caretaking function, officers may tow vehicles that impede vehicular traffic or jeopardize public safety but they may also impound vehicles that are in a high-crime area. Therefore, the officer's decision to impound the vehicle fell within the community caretaking exception because the vehicle was in a high-crime area. Affirmed.