The community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement allows a law-enforcement officer with objectively reasonable grounds to believe that there is an immediate need for his or her assistance to protect life or prevent serious injury to effect a community-caretaking/emergency-aid stop. 131 Ohio St.3d 325, 2012-Ohio-1008, ¶ 26, 964 N.E.2d 1037. In concluding that the community caretaking exception did not supply a valid basis for Trooper Byers's stop of Moiduddin's vehicle, the trial court found that the "totality of the circumstances * * * d[id] not suggest that there was an immediate need for assistance to protect life or prevent serious injury."

State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, syllabus.

The community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement allows a law-enforcement officer with objectively reasonable grounds to believe that there is an immediate need for his or her assistance to protect life or prevent serious injury to effect a community-caretaking/emergency-aid stop. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, syllabus. In Dunn, the Ohio Supreme Court cited ABA Standards for Criminal Justice § 1–2.2 for the proposition that "police officers are duty-bound to provide emergency services to those who are in danger of physical harm."

Another exception is the community-caretaking/emergency-aid exception which "allows police officers to stop a person to render aid if they reasonably believe that there is an immediate need for their assistance to protect life or prevent serious injury." State v. Dunn, 131 Ohio St. 3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 22.

{¶19} Under the community-caretaking/emergency aid exception to the Fourth Amendment, police officers may "stop a person to render aid if they reasonably believe that there is an immediate need for their assistance to protect life or prevent serious injury." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, syllabus. The exception recognizes that "local law-enforcement officers 'frequently investigate vehicle accidents in which there is no claim of criminal liability and engage in what, for want of a better term, may be described as community caretaking functions, totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.'"

State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24. In the case at bar, we conclude that appellant had not been placed in custody when he made these statements.

{¶29} Another is the "community-caretaking exception, which courts sometimes refer to as the 'emergency-aid exception' or 'exigent-circumstance exception.'" State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 15. "[Warrants are generally required to search a person's home or his person unless 'the exigencies of the situation' make the needs of law enforcement so compelling that the warrantless search is objectively reasonable under the Fourth Amendment."

This Court has previously observed as follows regarding the exigent-circumstances exception to the warrant requirement: "One such exception to the Fourth Amendment's warrant requirement is the community-caretaking exception, which courts sometimes refer to as the 'emergency-aid exception' or 'exigent-circumstance exception.'" See State v.Markins, 4th Dist. Scioto No. 10CA3387, 2013-Ohio-602, ¶ 20, quoting State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 15. {¶19} In Markins, we explained that under the exigent-circumstances exception," 'law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.'"

Under the community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement, Officer Kitchen had objective reasonable grounds to believe there was an immediate need for her assistance. See State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 26. {¶22} Therefore, her actions did not violate the Fourth Amendment.

{¶ 45} Appellant does not contest that Williamson's initial encounter with him was constitutional as it fell under the "community-caretaking/emergency-aid" exception to the Fourth Amendment warrant requirement, which "allows police officers to stop a person to render aid if they reasonably believe that there is an immediate need for their assistance to protect life or prevent serious injury." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, syllabus. In this case, appellant was found asleep, slumped over the steering wheel of a car at 11:30 a.m. From this fact, we agree that it is reasonable to believe that appellant may be in need of immediate medical assistance due to possible intoxication or drug overdose.