Erving Sanders v. State of Indiana
989 N.E.2d 332
| Ind. | 2013Background
- On Jan. 28, 2011 an IMPD officer stopped Erving Sanders’ 1991 Suburban for allegedly having rear side and back windows so tinted that occupants could not be "easily identified," citing Indiana’s Window Tint Statute.
- At the driver's window the officer smelled marijuana; Sanders allegedly admitted recent marijuana use.
- The officer ran Sanders’ license, requested backup, and when an assisting officer arrived Sanders was asked to exit, searched, and a plastic bag with a white substance was recovered; Sanders allegedly identified it as cocaine and was arrested.
- Sanders moved to suppress, arguing the stop/search were illegal because the vehicle’s tint later tested (by Sanders’ expert) within statutory limits (38% light transmittance).
- The trial court denied the motion, finding the officer had a good-faith belief a violation occurred; the Court of Appeals reversed, but the Indiana Supreme Court granted transfer and reviewed de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was lawful where the officer mistakenly believed the window tint violated the statute | Stop lawful: officer had reasonable, good-faith belief a tint violation occurred | Stop unlawful: tint later proved compliant, so officer lacked an objectively justifiable reason; stop was pretextual | Stop lawful: officer's reasonable suspicion and good-faith belief justified the stop despite subsequent proof of compliance |
| Whether the officer's mistake vitiates statutory authorization to detain under Ind. Code § 34-28-5-3 | Officer acted under a valid statutory belief authorizing brief detention | Mistake negates "good faith" under § 34-28-5-3; Ransom controls | Distinguished Ransom; because the supposed infraction exists in law and the belief was reasonable, detention was authorized |
| Whether evidence found after the stop/search should be suppressed under the Fourth Amendment | Evidence admissible if initial stop and search were lawful | Evidence fruit of unlawful stop/search and must be suppressed | Evidence admissible: officer smelled marijuana at the stop (probable cause) and search of person was lawful, so cocaine properly seized |
| Standard of review for suppression denial | Trial court denial should be sustained if supported by substantial probative evidence | Appellant seeks de novo review of reasonable suspicion; factual conflicts resolved for trial court | Court applied deferential review to facts and de novo review to reasonable-suspicion legal question; upheld trial court |
Key Cases Cited
- Taylor v. State, 689 N.E.2d 699 (Ind. 1997) (standard for reviewing suppression rulings and resolving evidence in support of trial court)
- Myers v. State, 839 N.E.2d 1154 (Ind. 2005) (reasonable-suspicion determinations reviewed de novo)
- Ornelas v. United States, 517 U.S. 690 (1996) (legal questions about reasonable suspicion/probable cause reviewed de novo)
- Mapp v. Ohio, 367 U.S. 643 (1961) (Fourth Amendment protections applied to the states)
- Berry v. State, 704 N.E.2d 462 (Ind. 1998) (warrantless searches and exceptions such as probable cause)
- Robles v. State, 510 N.E.2d 660 (Ind. 1987) (probable cause as an exception to warrant requirement)
- Meredith v. State, 906 N.E.2d 867 (Ind. 2009) (traffic stop and limited search permissible on reasonable suspicion)
- Ransom v. State, 741 N.E.2d 419 (Ind. Ct. App. 2000) (officer mistake about a non-existent infraction cannot justify a stop; distinguished here)