Erving Sanders v. State of Indiana
981 N.E.2d 616
Ind. Ct. App.2013Background
- Sanders stopped by Indianapolis Metropolitan Police Officer Minch around 4:30 p.m. 1/28/2011 for rear-window tint on a blue Suburban.
- Officer Minch smelled marijuana; Sanders admitted he had “just smoked a joint.”
- Sanders was searched; officers found a substance Sanders said was cocaine and he was arrested.
- Sanders was charged with possession of cocaine (Class D felony).
- Sanders moved to suppress the evidence on 5/4/2011; suppression hearings held 5/4, 6/1, 11/16/2011.
- In 11/2011, an expert later measured window tint; by 1/18/2012 the court found tint not unlawful but reserved the suppression ruling; the trial court denied suppression, and Sanders pursued interlocutory appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was lawful given tint evidence. | Sanders argues Minch’s belief about tint was mistaken and not a valid basis for a stop. | State contends tint violation provided reasonable suspicion for the stop. | Stop lacked reasonable suspicion; suppression reversed. |
Key Cases Cited
- State v. Sitts, 926 N.E.2d 1118 (Ind. Ct. App. 2010) (Fourth Amendment stops based on reasonable suspicion; totality of circumstances)
- State v. Rager, 883 N.E.2d 136 (Ind. Ct. App. 2008) (Good faith alone not enough; mistaken belief about a violation defeats suppression)
- Ransom v. State, 741 N.E.2d 419 (Ind. Ct. App. 2000) (Good-faith exception limitations; cannot rely on officer’s mistaken understanding)
- Cash v. State, 593 N.E.2d 1267 (Ind. Ct. App. 1992) (Quotations on the role of good faith in Fourth Amendment stops)
- Ornelas v. United States, 517 U.S. 690 (1996) (Standard of review for reasonable suspicion; totality of the circumstances)