Posted on: August 23rd, 2018

Terry Lee Coffman and his wife were sitting in their vehicle, which was parked on the side of the highway in Slater, Iowa. At approximately 1:08 a.m., a Sheriff’s Deputy, Nicholas Hochberger, was patrolling the area when he spotted Coffman’s vehicle on the roadside with its brake lights on. Deputy Hochberger turned on his flashing lights and stopped his patrol car behind Coffman’s vehicle. He immediately exited the patrol car and walked to the driver’s side window of the parked vehicle. While walking pass the rear of Coffman’s vehicle, Deputy Hochberger observed a registration violation. When he reached the driver’s window, he “immediately detected a strong odor of alcoholic beverage and noticed the driver’s red and watery eyes.” Deputy Hochberger asked the vehicle’s occupants if they were okay and Coffman and his wife responded in the affirmative. He then asked them what was going on and Coffman responded that he had pulled over on the side of the road to give his wife a back rub because she was having problems with her neck. Deputy Hochberger then asked Coffman for his license and registration. He also questioned Coffman about how much alcohol he had that night and Coffman responded that he had four beers. Deputy Hochberger administered a preliminary breath test and field sobriety tests, which showed Coffman was under the influence of alcohol. Coffman was arrested and later charged with OWI, first offense. Prior to his trial, Coffman filed a motion to suppress, arguing that the evidence obtained from Deputy Hochberger’s stop should be thrown out because the stop violated his rights under the Fourth Amendment of the U.S. Constitution and article I, section 8 of the Iowa Constitution. At the suppression hearing, Deputy Hochberger testified that he regularly stopped behind vehicles that were pulled over on the roadside in order to “check on the welfare of the occupants or see if they need any assistance.” The district court denied Coffman’s motion to suppress and he was convicted of OWI, first offense. The Iowa Court of Appeals affirmed Coffman’s conviction and he appealed to the Iowa Supreme Court.

In his appeal to the Supreme Court, Coffman contended that his conviction should be overturned because the district improperly denied his motion to suppress. He argued that he was lawfully parked on the side of the highway and that Deputy Hochberger’s actions violated his federal and state constitutional rights against unreasonable searches and seizures. The Supreme Court rejected Coffman’s arguments, finding Deputy Hochberger’s seizure of Coffman’s vehicle constitutional under the community caretaking exception to the warrant requirement under both the Fourth Amendment of the U.S. Constitution and article I, section 8, of the Iowa Constitution. The court noted that although Deputy Hochberger’s actions constituted a seizure under the Fourth Amendment, it fell within the community caretaking exception because Deputy Hochberger had a bona fide caretaker objective when he pulled behind Coffman’s car (to check if the passengers needed assistance). Further, “the public interest in having officers check on the welfare of a motorist pulled over at the side of a highway in the middle of the night is significant” and outweighs the intrusion on Coffman’s privacy. The Court also held that “under the Iowa Constitution, a community caretaking seizure of a vehicle must be undertaken for genuine community caretaking purposes.” It concluded that Deputy Hochberger’s actions fell within the community caretaking exception and affirmed Coffman’s conviction.

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