Com. v. Enyeart, R.
Com. v. Enyeart, R. No. 90 WDA 2016
| Pa. Super. Ct. | Jul 19, 2017Background
- Trooper Meko observed Enyeart’s vehicle “nudging” the center line and once crossing the right fog line after a curve; dash-cam video showed limited similar movement.
- Meko smelled alcohol and marijuana, stopped the vehicle for suspected DUI, and administered field sobriety tests; he testified those tests indicated probable impairment.
- Enyeart was arrested, consented to a blood draw after being given implied-consent warnings, and blood results showed THC and a BAC of .082.
- Enyeart moved to suppress evidence from the stop; the trial court denied suppression and the jury convicted Enyeart of DUI under 75 Pa.C.S.A. § 3802(d)(1)(i) (controlled substance), but acquitted on certain summary traffic offenses; a demurrer was granted on the 75 Pa.C.S.A. § 3802(a)(2) BAC-based charge.
- The dissenting judge (Lazarus, J.) would reverse, concluding the initial stop lacked reasonable suspicion and all derivative evidence should be excluded.
Issues
| Issue | Appellee's Argument (Commonwealth) | Appellant's Argument (Enyeart) | Held |
|---|---|---|---|
| Was the traffic stop supported by reasonable suspicion of DUI? | Trooper observed swerving, straddling center line, crossing fog line and smelled alcohol/marijuana — sufficient for reasonable suspicion. | Momentary “nudging” and brief fog-line crossing (after a curve), plus equivocal pre-MVR observations, were insufficient for reasonable suspicion. | Dissent: stop was unlawful for lack of reasonable suspicion (would reverse). Trial court had found reasonable suspicion. |
| Should evidence from the stop/blood draw be suppressed if the stop was unlawful? | Evidence admissible because stop was justified by reasonable suspicion. | All evidence should be excluded as fruit of unlawful stop. | Dissent: suppression required; trial court denied suppression. |
| Did field sobriety tests and officer observations support probable cause for arrest? | Officer’s observations and SFST clues indicated probable impairment justifying arrest. | Officer’s observations were equivocal and insufficient to elevate to probable cause absent a lawful stop. | Trial court and majority found arrest justified post-stop; dissent disputes sufficiency. |
| Is conviction for driving under the influence of a controlled substance supported? | Blood test detected THC; expert testified regarding testing; conviction for §3802(d)(1)(i) supported. | Conviction tainted if stop/arrest unlawful; also challenges to evidentiary reliability were raised. | Jury convicted on controlled-substance DUI; dissent would reverse based on suppression issue. |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes standard for stops based on reasonable suspicion)
- Commonwealth v. Rogers, 849 A.2d 1185 (Pa. 2004) (discusses reasonable suspicion and totality-of-circumstances analysis)
- Commonwealth v. Sands, 887 A.2d 261 (Pa. 2005) (upheld DUI stop where multiple drifts across fog line supported suspicion)
- Commonwealth v. Cook, 735 A.2d 673 (Pa. 1999) (courts must give weight to reasonable inferences from officer experience)
- Commonwealth v. Reppert, 814 A.2d 1196 (Pa. Super. 2002) (reasonable suspicion requires particularized and objective basis)
- Commonwealth v. Melendez, 676 A.2d 226 (Pa. 1996) (officer must point to specific and articulable facts to justify a stop)
- Commonwealth v. Zhahir, 751 A.2d 1153 (Pa. 2000) (reasonableness measured by whether facts warranted a prudent person’s belief)
- Commonwealth v. Salter, 121 A.3d 987 (Pa. Super. 2015) (reasonable suspicion under vehicle-code stop standards)
- Commonwealth v. Hughes, 908 A.2d 924 (Pa. Super. 2006) (upheld DUI stop where repeated swerving crossed into other lane)