Haynes v. State
937 N.E.2d 1248
Ind. Ct. App.2010Background
- Haynes was convicted of operating a motor vehicle while privileges are forfeited for life, a Class C felony.
- Gas City Police observed Haynes illegally parked in a handicap spot without a placard or license plate visible.
- Officer McCollum approached, Haynes claimed no placard and that his privileges were suspended and he was a habitual traffic violator.
- Officer McCollum verified Haynes was a lifetime habitual traffic violator via BMV records and arrested him.
- Haynes filed a Motion to Suppress Evidence; the trial court denied it after a bench trial.
- The trial court sentenced Haynes to five years’ imprisonment; the case on appeal concerns suppression and stop legality.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop and detention violated the Fourth Amendment/Indiana Constitution. | Haynes contends McCollum lacked reasonable suspicion to stop him. | Haynes argues no traffic violations occurred and no authority to detain. | Stop was lawful; reasonable suspicion supported detention. |
Key Cases Cited
- State v. Quirk, 842 N.E.2d 334 (Ind. 2006) (standard for reviewing suppression rulings; substantial evidence required)
- Moultry v. State, 808 N.E.2d 168 (Ind.Ct.App. 2004) (Terry-type stop requires reasonable suspicion)
- Turner v. State, 862 N.E.2d 695 (Ind.Ct.App. 2007) (Indiana analysis of constitutionality of police stops under totality of circumstances)
- Coleman v. State, 847 N.E.2d 259 (Ind.Ct.App. 2006) (separate analysis under Indiana Constitution for warrantless searches)
- State v. Medlar, 93 Ohio App.3d 483, 638 N.E.2d 1105 (Ohio Ct. App. 1994) (parking violation enforcement and pretextual stops distinguished)
- State v. Holmes, 569 N.W.2d 181 (Minn. 1997) (parking violation stop and subsequent search analyzed for necessity)