Joanna S. Robinson v. State of Indiana
985 N.E.2d 1141
Ind. Ct. App.2013Background
- Deputy observed Robinson briefly touch the fog line on a curvy, nighttime road and stop was made for unsafe lane movement.
- Robinson admitted drinking one beer; her eyes were glossy and breath smelled of alcohol; she failed three field sobriety tests.
- A breath test at jail showed .09 BAC; Robinson disclosed marijuana in her bra.
- The trial court found brief fog-line contact could support a stop but later suppressed the stop’s evidence if not supported by reasonable suspicion.
- On appeal, court reviews admissibility of evidence de novo for reasonable suspicion and reverses when stop is unsupported.
- Convictions hinged on evidence obtained from the stop which the court deems improper under the Fourth Amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was supported by reasonable suspicion. | State argues impairment shown by fog-line contact and other observations. | Robinson contends brief fog-line contact on a curvy road at night is insufficient. | No reasonable suspicion; stop improper; convictions reversed. |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (standard for reasonable suspicion; totality of circumstances)
- United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (totality of circumstances framework for reasonable suspicion)
- Barrett v. State, 837 N.E.2d 1022 (Ind. Ct. App. 2005) (brief fog-line contact not alone sufficient for suspiciousness; Barrett discussed and distinguished)