Cady, subsequent federal and state decisions (other than those of Illinois, New Mexico, North Dakota, and Tennessee) consistently describe the doctrine as an exception to the Fourth Amendment’s restrictions on warrantless searches and seizures. See, e.g., Lockhart-Bembery v. Sauro, 498 F.3d 69, 75 (1st Cir.2007) (observing that the question is not “whether there was a seizure” because, “under the community caretaking doctrine, police action can be constitutional notwithstanding the fact that it constitutes a seizure.”); United States v. Coccia, 446 F.3d 233, 237-38 (1st Cir.2006) (“Generally, a law enforcement officer may only seize property pursuant to a warrant based on probable cause describing the place to be searched and the property to be seized. There are, however, exc (2009) (<HOLDING>); People v. Slaughter, 489 Mich. 302, 803
recognizing that the community caretaking exception is distinct from the emergency aid or emergency assistance exception to the fourth amendment warrant requirement recognizing that police perform a community caretaking function separate and apart from the enforcement of criminal statutes recognizing a discretionary function exception to that waiver recognizing that the community caretaking function as an exception and enunciating a test for its application recognizing the community caretaking exception but holding it inapplicable to justify the police action at issue