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State v. Hanson

Supreme Court of Minnesota
Aug 16, 1993
504 N.W.2d 219 (Minn. 1993)

Summary

holding officer's actions of pulling behind a vehicle parked on a highway shoulder and activating the squad's flashing emergency lights did not constitute seizure because " reasonable person would know that while flashing lights may be used as a show of authority, they also serve other purposes, including warning oncoming motorists in such a situation to be careful."

Summary of this case from United States v. Cook

Opinion

No. C3-92-2329.

August 16, 1993.

Appeal from the District Court, Scott County, Thomas R. Howe, J.


ORDER

Based upon all the files, records and proceedings herein,

IT IS HEREBY ORDERED (1) that the petition of the State of Minnesota for further review of the decision of the court of appeals be, and the same is, granted and (2) that the decision of the court of appeals, 501 N.W.2d 677, is reversed and the judgment of conviction of driving with a blood alcohol concentration of .10 or more is reinstated.

The court of appeals based the reversal of defendant's conviction on its conclusion that the chemical test results were the suppressible fruit of an unlawful stop or "seizure" of defendant. The court of appeals in effect held that if a police officer sees a car stopped on the shoulder of a highway at night and, with no reason to suspect criminal activity, drives up behind the car in order to see if the driver needs help, the use by the officer of his or her flashing red lights, even to warn oncoming motorists, will turn the encounter into a Fourth Amendment seizure and any evidence discovered — drunkenness of the driver, dead body in open view in the back seat, etc. — will be the suppressible fruit of the unjustified "stop."

Under the so-called Mendenhall/Royer approach which we follow in determining whether a "seizure" has occurred — see In the Matter of the Welfare of E.D.J., 502 N.W.2d 779 (Minn., 1993) — the question to be asked by the reviewing court is whether, looking at all of the facts, the conduct of the police would communicate to a reasonable person in the defendant's physical circumstances an attempt by the police to capture or seize or otherwise to significantly intrude on the person's freedom of movement. See Michigan v. Chesternut, 486 U.S. 567, 572-75, 108 S.Ct. 1975, 1978-80, 100 L.Ed.2d 565 (1988).

See United States v. Mendenhall, 446 U.S. 544, 554-55, 100 S.Ct. 1870, 1877-78, 64 L.Ed.2d 497 (1980), and Florida v. Royer, 460 U.S. 491, 501, 103 S.Ct. 1319, 1326, 75 L.Ed.2d 229 (1983).

The problem with the court of appeals decision is that it in effect says that whenever an officer turns on the squad car's flashing red lights before getting out and approaching an already stopped car, the officer turns the encounter into a seizure. It may be that in many fact situations the officer's use of the flashing lights likely would signal to a reasonable person that the officer is attempting to seize the person for investigative purposes. In this case, however, under all the facts, the officer's conduct would not have communicated to a reasonable person in these physical circumstances that the officer was attempting to seize the person. A reasonable person would have assumed that the officer was not doing anything other than checking to see what was going on and to offer help if needed. A reasonable person in such a situation would not be surprised at the use of the flashing lights. It was dark out and the cars were on the shoulder of the highway far from any town. A reasonable person would know that while flashing lights may be used as a show of authority, they also serve other purposes, including warning oncoming motorists in such a situation to be careful.

Accordingly, we reverse the court of appeals' decision and reinstate defendant's conviction.


Summaries of

State v. Hanson

Supreme Court of Minnesota
Aug 16, 1993
504 N.W.2d 219 (Minn. 1993)

holding officer's actions of pulling behind a vehicle parked on a highway shoulder and activating the squad's flashing emergency lights did not constitute seizure because " reasonable person would know that while flashing lights may be used as a show of authority, they also serve other purposes, including warning oncoming motorists in such a situation to be careful."

Summary of this case from United States v. Cook

holding that an officer's use of flashing lights may be designed to warn oncoming motorists

Summary of this case from Reese v. Comm. of Public Safety

finding no seizure where officer activated flashing red lights before approaching vehicle parked on highway shoulder at night

Summary of this case from United States v. Cook

finding no seizure where officer activated flashing red lights before approaching vehicle parked on highway shoulder at night

Summary of this case from State v. Levell

finding no seizure by officer checking to determine if help is needed

Summary of this case from State v. Henderson

concluding no seizure occurred where officer, suspecting no criminal activity, activated red flashing lights upon approaching an already-stopped vehicle

Summary of this case from State v. Anderson

concluding there was no seizure where officer, suspecting no criminal activity, activated flashing red lights upon approaching already stopped car

Summary of this case from State v. Bergerson

reversing the appellate court's finding that whenever a police officer, with no reason to suspect criminal activity, drives up behind a parked vehicle and activates his or her flashing red lights, the encounter is converted into a Fourth Amendment seizure

Summary of this case from G.M. v. State

noting that an officer's use of flashing squad lights in many situations "would signal to a reasonable person that the officer is attempting to seize the person for investigative purposes"

Summary of this case from State v. Smith

In Hanson, the supreme court stated that a seizure does not necessarily occur when an officer turns on the squad car's emergency lights before approaching an already stopped car on the shoulder of the road.

Summary of this case from Mix v. Comm'r of Pub. Safety

stating that a seizure occurs when, "looking at all of the facts, the conduct of the police would communicate to a reasonable person in the defendant's physical circumstances an attempt by the police to capture or seize or otherwise to significantly intrude on the person's freedom of movement"

Summary of this case from State v. Otto

deeming erroneous a holding “that whenever an officer turns on the squad car's flashing red lights before getting out and approaching an already stopped car, the officer turns the encounter into a seizure”

Summary of this case from Dolores v. Comm'r Safety

stating that the question to be asked is whether, "looking at all of the facts, the conduct of the police would communicate to a reasonable person in the defendant's physical circumstances an attempt by the police to capture or seize or otherwise to significantly intrude on the person's freedom of movement"

Summary of this case from State v. Pettinelli

In Hanson, the supreme court concluded that an objectively reasonable interpretation of the officer's decision to use emergency lights was that he was warning passing motorists of the stopped car.

Summary of this case from State v. Bell

In Hanson, the officer observed a car stopped on the shoulder of a highway at night far from any town, activated his emergency lights, and pulled behind it.

Summary of this case from State v. McCalip

discussing possible messages conveyed by flashing lights

Summary of this case from State v. Bahneman

noting that an "officer's use of the flashing lights likely would signal to a reasonable person that the officer is attempting to seize the person for investigative purposes"

Summary of this case from State v. Baker

stating that question reviewing court must ask is whether in light of totality of circumstances police conduct would have communicated to reasonable person that he or she was not free to leave

Summary of this case from STATE v. DEML

stating that "in many fact situations the officer's use of the flashing lights likely would signal to a reasonable person that the officer is attempting to seize the person for investigative purposes"

Summary of this case from State v. Just

In Hanson, the officer saw a vehicle stopped on the shoulder of a highway at night, activated the emergency lights to warn oncoming motorists, and pulled in behind the vehicle to see if the driver needed any assistance. 504 N.W.2d at 219-20.

Summary of this case from State v. Lopez

In Hanson, the court stated that "[a] reasonable person would have assumed that the officer was not doing anything other than checking to see what was going on and to offer help."

Summary of this case from Oehrlein v. Commr. of Public Safety

In Hanson, the supreme court held that an officer's use of his flashing red lights behind a stopped vehicle on the shoulder of the highway at night does not necessarily turn the encounter into Fourth Amendment seizure.

Summary of this case from JUUL v. COMMR. OF PUBLIC SAFETY

arguing "in many fact situations the officer's use of the flashing lights likely would signal to a reasonable person that the officer is attempting to seize the person for investigative purposes"

Summary of this case from State v. Gangl
Case details for

State v. Hanson

Case Details

Full title:STATE of Minnesota, Respondent, v. Steven M. HANSON, Appellant

Court:Supreme Court of Minnesota

Date published: Aug 16, 1993

Citations

504 N.W.2d 219 (Minn. 1993)

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