The New York Court of Appeals has held, for the first time, that a police officer may stop a vehicle under the “community caretaking doctrine,” provided the stop meets certain criteria that ensure a citizen’s protection under the Fourth Amendment.

In People v. Brown, 2024 N.Y. Slip 02765 (2024), the court joined approximately 25 other states, which have recognized community caretaking as a valid public safety function of the police, based on an objectively reasonable belief that someone is in need of assistance. (see LaFave, “Search and Seizure: A Treatise on the Fourth Amendment,” (6th Ed. at Section 7.4[f]; Commonwealth v. Livingstone, 649 Pa 27 (2017) (collecting cases).