State v. Dunn,131 Ohio St.3d 325, 2012-Ohio-1008.

{¶16} Finally, we note that 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, 964 N.E.2d 1037, syllabus. In Dunn, the police responded to a dispatch that there was a suicidal male driving a tow truck and that he was planning to kill himself.

For example, the Ohio Supreme Court has recently held that threats of suicide falls under the "community caretaking/emergency aid" exception to the Fourth Amendment warrant requirement and allow police officers to stop a vehicle when the driver has made threats of suicide. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, ¶ 22. Thus, in order to comply with the Fourth Amendment, police officers must at least possess probable cause to arrest in cases of exigent circumstances.

This is so because "the requirement that police officers administer Miranda warnings applies only when a suspect is subjected to both custody and interrogation." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24 In other words, "Miranda rights only attach when both custody and interrogation coincide." State v. Tellington, 9th Dist. No. 22187, 2005-Ohio-470, ¶ 8, citing State v. Wiles, 59 Ohio St.3d 71, 83, 571 N.E.2d 97 (1991).

{¶8} In order for Miranda's safeguards to apply, a suspect must be in "custody" and subject to "interrogation." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24. Whether a suspect is in custody turns on whether there is a "'formal arrest or restraint on freedom of movement' of the degree associated with a formal arrest." California v. Beheler, 463 U.S. 1121, 1125, 77 L.Ed.2d 1275, 103 S.Ct. 3517 (1983) (per curiam), quoting Oregon v. Mathiason, 429 U.S. 492, 495, 50 L.Ed.2d 714, 97 S.Ct. 711 (1977) (per curiam).

{¶17} "[T]he requirement that police officers administer Miranda warnings applies only when a suspect is subjected to both custody and interrogation." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24, citing Miranda, supra. "The Court in Miranda required suppression of many statements that would have been admissible under traditional due process analysis by presuming that statements made while in custody and without adequate warnings were protected by the Fifth Amendment."

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." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 15. {¶21} "Numerous state and federal cases have recognized that the Fourth Amendment does not bar police officers from making warrantless entries and searches when they reasonably believe that a person within is in need of immediate aid."

{¶23} But police may also stop a vehicle pursuant to their community caretaker function. The Ohio Supreme Court recently examined the community caretaker function in State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶17: The [United State Supreme Court in Cady v. Dombrowski, 413 U.S. 433, 93 S.Ct. 2523, 37 L.Ed.2d 706 (1973)] court explained 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."

eb. 372, 730 N.W.2d 335, 338 (2007) (“[W]e hereby adopt the community caretaking exception to the Fourth Amendment.”); State v. Rincon, 122 Nev. 1170, 147 P.3d 233, 237 (2006) (adopting the community caretaking exception to the Fourth Amendment); State v. Boutin, 161 N.H. 139, 13 A.3d 334, 337 (2010) (discussing prior New Hampshire cases applying the community caretaking exception); State v. Edmonds, 211 N.J. 117, 47 A.3d 737, 752 (2012) (“The community-caretaking doctrine is an exception to the warrant requirement, not a roving commission to conduct a nonconsensual search of a home in the absence of exigent circumstances.”); Ryon, 2005–NMSC–005, ¶ 20, 108 P.3d at 1041 (acknowledging that its earlier description of community caretaking as a form of consensual encounter “was wrong” and cautioning that certain prior decisions should “not be viewed as limiting the community caretaker exception to voluntary or consensual police-citizen encounters”); State v. Dunn, 2012–Ohio–1008, at ¶ 22, 131 Ohio St.3d 325, 964 N.E.2d 1037, 1042 (2012) (“Thus, we hold that the community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement 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.”); Coffia v. State, 2008 OK CR 24, ¶¶ 10–13, 191 P.3d 594, 597–98 (2008) (discussing the community caretaking exception to the Fourth Amendment); State v. Wood, 149 P.3d 1265, 1267–68 (Or.Ct.App.2006) (describing an Oregon statute as a community caretaking exception to the warrant requirement); State v. Deneui, 2009 SD 99, ¶ 33, 775 N.W.2d 221, 235 (2009) (“The community caretaker exception has been recognized only in the context of automobiles by the United States Supreme Court.” (citing Cady v. Dombrowski, 413 U.S. 433, 441, 93 S.Ct. 2523, 37 L.Ed.2d 706 (1973)));

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.