Jose M. Santana v. State of Indiana
10 N.E.3d 76
Ind. Ct. App.2014Background
- Officer Burks observed Santana commit a traffic infraction by not signaling for the required distance, justifying a stop under Indiana law.
- Burks ran Santana's license plate; one digit was omitted, resulting in a 'Not on File' result at first.
- Santana did not have a license; he produced a Mexican voter registration card; the truck registration was valid.
- Officer Burks learned Santana had been adjudicated a Habitual Traffic Offender, resulting in lifetime forfeiture of driving privileges, and Santana was charged with a Class C felony.
- Santana moved to suppress the stop; the trial court denied the motion; Santana was convicted after a bench trial.
- On appeal, the admissibility standard governs whether the stop was valid based on an objectively justifiable reason.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop supported by a valid traffic violation? | Santana argues no valid stand-alone basis for stop. | State contends signaling violation provided valid basis. | Yes; stop supported by 200-foot signaling requirement. |
Key Cases Cited
- Turner v. State, 862 N.E.2d 695 (Ind. Ct. App. 2007) (no reweighing of conflicting evidence; reasonable suspicion standard applied)
- Haynes v. State, 937 N.E.2d 1248 (Ind. Ct. App. 2010) (officer testimony of traffic infraction suffices to justify stop)