Mark Wayne Gaddy v. Oklahoma

In Cady v. Dombrowski, 413 U.S. 433 (1973), this Court recognized the “community caretaking” function of police. In Florida v. J.L., 529 U.S. 266 (2000), this Court held that an anonymous phone call, without more, is insufficient to support a police body frisk for a gun. Here, police received an anonymous phone call on an unrecorded non-emergency phone line that a woman was in a car asleep in a Wal-Mart parking lot. No indication of a medical emergency, criminal activity, or any other emergent circumstances. From this, police watched the car drive by, observed the woman awake and in no distress, and stopped the car on that basis alone, with a resulting request for driving documents, consents to search, and searches of the persons and the car. The Oklahoma Court of Criminal Appeals ruled that the traffic stop comported with the Fourth Amendment under the community caretaking function, with a dissent by the Presiding Judge. The question presented is whether the decision of the Oklahoma Court of Criminal Appeals is an unwarranted extension of the community caretaking function of Cady, and also in direct conflict with this Court’s understanding of anonymous phone calls in J.L.