192 A.3d 945
Md. Ct. Spec. App.2018Background
- Ronald Baez was stopped in Prince George’s County after officers observed window tinting exceeding Maryland’s legal limit; the vehicle was registered in Virginia.
- Parties stipulated the stop was for a tint violation and that the car had excessive tint; officers later smelled marijuana, searched the car, and found ~747 grams of marijuana.
- Baez moved to suppress the evidence, arguing the stop was unlawful because § 22-406’s tint restriction applies only to Maryland-registered vehicles.
- The trial court denied the motion to suppress, convicted Baez of possession of marijuana, and imposed an agreed sentence.
- On appeal, Baez’s sole issue was whether police had reasonable articulable suspicion to stop the vehicle solely for a window-tint violation when the car was registered out-of-state.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a stop based solely on suspected window-tint violation is lawful for an out-of-state registered vehicle | Baez: Maryland tint statute applies only to Maryland-registered vehicles, so no lawful basis to stop his Virginia-registered car | State: Officer had reasonable articulable suspicion of a tint (or other safety) violation while vehicle was on Maryland highways; registration location doesn’t negate suspicion | Stop was lawful: officer may stop to investigate suspected tint violation; out-of-state registration does not vitiate the stop |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (traffic-stop reasonableness assessed objectively)
- United States v. Stanfield, 109 F.3d 976 (4th Cir.) (danger to officers from heavily tinted windows)
- Turkes v. State, 20 A.3d 173 (Md. Ct. Spec. App.) (tint violation can supply reasonable articulable suspicion for a stop)
- Muse v. State, 807 A.2d 113 (Md. Ct. Spec. App.) (officers need only reasonable suspicion at investigatory stage)