Joanna S. Robinson v. State of Indiana
2014 Ind. LEXIS 251
Ind.2014Background
- Deputy Claeys followed Robinson's vehicle on County Road 4 and stopped it for unsafe lane movement after it drifted toward the white fog line twice.
- Upon approach, Robinson showed signs of intoxication (glossy eyes, slurred speech) and admitted drinking one beer; odor of alcohol observed.
- Robinson failed standard field sobriety tests and disclosed marijuana, which she removed and dropped to the ground.
- Robinson was arrested and subjected to a chemical BAC test showing 0.09%; charged with three Class A misdemeanors and one Class C misdemeanor.
- Robinson moved to suppress the evidence, arguing the stop lacked reasonable suspicion; the trial court denied the motion after weighing Deputy Claeys’s testimony against video; Robinson appealed and the Court of Appeals’ decision was vacated and transferred.
- The core issue is whether the stop was supported by reasonable suspicion under the Fourth Amendment and Indiana Constitution Article 1, § 11, considering conflicting video and testimonial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop supported by reasonable suspicion under the Fourth Amendment? | Robinson contends no reasonable suspicion; he emphasizes the video did not show leaving the road. | State argues the officer observed multiple movements onto the fog line indicating impairment, sufficient for a stop. | Yes; reasonable suspicion supported the stop under the Fourth Amendment. |
| Was the stop reasonable under Indiana Constitution Article 1, § 11 under the totality of circumstances? | Robinson argues the Stop violated §11 given the video evidence and lack of corroborating tip. | State contends totality of circumstances supports a reasonable stop to prevent alcohol-impaired driving. | Yes; stop reasonable under Article 1, § 11. |
Key Cases Cited
- Barrett v. State, 837 N.E.2d 1022 (Ind.Ct.App.2005) (drifting onto fog line supports reasonable suspicion (impaired driving))
- McCaa v. State, 968 N.E.2d 24 (Ind.Ct.App.2012) (multiple movements toward fog line justify stop for suspicion)
- Jaremczuk v. State, 380 N.E.2d 615 (Ind.App.1978) (fog line movement as basis for stop under suspected impairment)
- State v. Washington, 898 N.E.2d 1200 (Ind.2008) (Indiana Article 1, § 11 analysis requires totality-of-circumstances review)
- Scott v. Harris, 550 U.S. 372 (U.S.2007) (video may reflect limits of eyewitness testimony; appellate review does not reweigh all evidence)
- Virginia v. Harris, 558 U.S. 978 (U.S.2009) (dissenting view cited on need for reasonable suspicion, not strict literal rule)
- Benham v. State, 637 N.E.2d 133 (Ind.1994) (affirmance on any basis in the record)