Commonwealth v. Aziz

87 Va. Cir. 38, 2013 Va. Cir. LEXIS 152
CourtCharlottesville County Circuit Court
DecidedJune 28, 2013
DocketCase No. 13-3-01
StatusPublished

This text of 87 Va. Cir. 38 (Commonwealth v. Aziz) is published on Counsel Stack Legal Research, covering Charlottesville County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Aziz, 87 Va. Cir. 38, 2013 Va. Cir. LEXIS 152 (Va. Super. Ct. 2013).

Opinion

By Judge Edward L. Hogshire

Defendant Raashon Aziz, having been indicted for being a violent felon in possession a firearm, has filed a Motion to Suppress evidence of any and all firearms, ammunition, and related physical evidence. Defendant alleges that such evidence was obtained through an unreasonable search and seizure and in violation of his rights as guaranteed under the Fourth Amendment to the U.S. Constitution. The motion was heard ore terms on May 24, 2013. Having considered the evidence presented, along with legal memoranda and the arguments of counsel, for the reasons stated below, the Court will deny Defendant’s Motion to Suppress.

Statement of Facts

The statement of facts is derived from the testimony presented at the May 24, 2013, hearing.

The facts adduced at the evidentiary hearing revealed that, on the morning of November 23, 2012, Defendant was asleep in his car that was parked at a gas pump at the BP station on Fontaine Avenue. Motion Hearing Transcript, 9, May 24, 2013. At approximately 7:10 a.m., the 911 operator dispatched officers G. E. Wade and C. N. Bowman of the Charlottesville Police Department to the scene. Id. at 33. The operator explained that there was a Suburban parked at the gas pump with loud music coming from it. Id. Additionally, there was a non-responsive male, later identified as the Defendant, in the vehicle, and there was a firearm potentially involved. Id. at 37. Both officers testified that, when they arrived at the scene they did not have any suspicion that criminal activity had occurred or was occurring. Id. at 52, 69. However, given the nature of the facts from the dispatcher, specifically with respect to the firearms, the officers cautiously approached [39]*39the vehicle. Id. at 37. Officer Wade noted that there was loud music emanating from the vehicle, the driver’s seat was in the reclined position, the driver’s side window was rolled down, and the Defendant appeared to be asleep in the driver’s seat. Id. As the officers continued to approach, they were able to obtain a better view of the inside of the vehicle and to confirm the presence of two guns. Id. at 40-41. There was a black semi-automatic handgun resting on the center console, and there was a shotgun facing downwards in the passenger-side floorboard. Id. Officer Wade testified that the Defendant’s arm was resting on the passenger seat and that his hand was very close to the butt of the shotgun. Id. at 41. And the handgun was located just to the right of the driver’s thigh. Id.

After observing the weapons, Officer Wade attempted to rouse the Defendant by shouting at him, several times, through the open window. Id. at 45. The Defendant did not respond. Id. At that time, Office Wade determined it would be necessary to make physical contact with the person, and he was concerned that the Defendant would be startled upon waking up and potentially discharge one of the guns. Id. at 45. Officer Wade analogized the situation to DUI stops that he had experienced where the motorist was asleep and was startled by being woken up. Id. at 43. Moreover, he testified that the police officers are trained to be cautious when making initial contact in situations of this nature, because of the uncertainty about how a person will react when you wake them up. Id. at 43. As a result of these concerns, Officer Bowman seized the weapons and placed them in the trunk of his vehicle prior Officer Wade making physical contact with the Defendant. Id. at 66. Finally, the officers were able to wake the Defendant by turning down the radio, shouting at him, and physically shaking him. Id. at 47.

Issue Presented

Whether the seizure of the guns was a violation of the Defendant’s right against unreasonable searches and seizures and, therefore, should be excluded.

Law

The Fourth Amendment protects people from unreasonable searches and seizures. Katz v. United States, 389 U.S. 347, 351, 88 S. Ct. 507, 511, 19 L. Ed. 2d 576, 582 (1967). Under the reasonableness inquiry, there is a strong preference for the issuance of a warrant prior to a search and seizure. Ornelas v. United States, 517 U.S. 690, 698, 116 S. Ct. 1657, 1663, 134 L. Ed. 2d 911, 920 (1996). However, given the facts of the present case, it is necessary to consider whether there is an exception that would permit a warrantless search and seizure in a situation where there is no suspicion of criminal activity. The most relevant exception is the community caretaker [40]*40doctrine.1 Commonwealth v. Waters, 20 Va. App. 285, 289, 456 S.E.2d 527, 529 (1995). This doctrine permits an officer to conduct warrantless investigative seizures when it is totally divorced from the detection of a crime and as long as the seizure is reasonable. Id.

The duty of the police embraces the function of maintaining public order and providing necessary assistance to persons in need or distress. An officer who harbors a reasonable and articulable suspicion, based upon observed facts or a credible report, that a citizen is in distress or in need of assistance, may lawfully effect an appropriately brief and limited seizure for the purpose of investigating that suspicion and rendering aid.

Waters, 20 Va. App. at 290, 456 S.E.2d at 529.

When assessing the reasonableness of the seizure, the court must first determine whether it was objectively reasonable, based on the totality of the circumstances, for the officer to believe that his initial actions were necessary either to aid the defendant or for the protection of (1) an owner’s property while it is in police custody, or (2) the police against claims or disputes concerning lost or stolen property, or (3) the public and the police from physical danger. Kyer v. Commonwealth, 43 Va. App. 603, 618, 601 S.E.2d 6, 13 (2004). Second, the seizure must be for the purpose of providing aid, and the intrusion must be limited. Id. Finally, the court must ensure that the community caretaker function is not being used as a pretext to investigate criminal conduct. Id. All three requirements must be fulfilled in order to apply the community caretaker doctrine, but the objective reasonableness requirement is the “linchpin of determining the validity of an action.” Waters, 20 Va. App. at 290, 456 S.E.2d at 529.

Virginia courts have assessed a variety of fact patterns to determine when the evidence is sufficient to satisfy the “linchpin” element. Typically, evidence of the defendant’s car being parked on the side of the road or being driven on the side of the road is not adequate, in and of itself, to generate a reasonable belief that assistance was needed. Barrett v. Commonwealth, 250 Va. 243, 462 S.E.2d 109 (1995) (holding that there was no reasonable indication that assistance was needed when a truck was moving with its wheels partially in a private yard); Commonwealth v. Geoffrey Andrew Peterson, No. CR07001470-00, 2008 Va. Cir.

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Related

Katz v. United States
389 U.S. 347 (Supreme Court, 1967)
Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
Ornelas v. United States
517 U.S. 690 (Supreme Court, 1996)
Barrett v. Commonwealth
462 S.E.2d 109 (Supreme Court of Virginia, 1995)
Commonwealth v. Waters
456 S.E.2d 527 (Court of Appeals of Virginia, 1995)
Kyer v. Commonwealth
601 S.E.2d 6 (Court of Appeals of Virginia, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
87 Va. Cir. 38, 2013 Va. Cir. LEXIS 152, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-aziz-vacccharlottesv-2013.