22 N.E.3d 730
Ind. Ct. App.2014Background
- At ~midnight on Feb. 15, 2014, Officer Packard observed a 1988 Oldsmobile whose passenger-side taillamp had a large hole that emitted overwhelming white light while the car moved.
- Packard testified he observed the vehicle from approximately 300–700 feet but could not state an exact 500-foot distance; he believed any white light from the rear in forward motion was an infraction under Ind. Code § 9-19-6-4.
- Packard initiated a traffic stop, detected a faint odor of marijuana, summoned a canine, and the dog alerted; officers recovered a bag of marijuana from Williams’s person.
- Williams was charged with Class A misdemeanor possession; he moved to suppress evidence gathered as a result of the traffic stop, asserting the stop was illegal.
- The trial court denied the suppression motion, convicted Williams, and sentenced him to 365 days with 363 suspended; the Court of Appeals reversed.
Issues
| Issue | State's Argument | Williams's Argument | Held |
|---|---|---|---|
| Whether Packard had reasonable suspicion to stop Williams for a taillamp infraction under Ind. Code § 9-19-6-4 | Packard reasonably suspected an infraction because the taillamp emitted predominant white light that "overwhelmed" red | The stop was illegal because the statute requires red light to be plainly visible from 500 feet, and the record does not show red was not plainly visible or that Packard observed from 500 ft | Reversed: stop was unlawful — officer’s observation did not establish a prima facie violation; Packard’s belief was a legal mistake, not reasonable suspicion |
| Whether a mistaken belief about the law can justify a stop | Officer’s good-faith belief can justify a stop if based on observations making a prima facie case (relying on Sanders) | Packard’s belief was not grounded in facts making out the statutory violation and thus not good-faith reasonable suspicion | Held: mistaken belief here was not good faith because the statute does not prohibit non-red light or predominant non-red light; Packard never said red was not plainly visible |
| Whether the evidence seized should be suppressed because the stop was illegal | Stop was lawful so ensuing evidence admissible | Evidence was the fruit of an illegal stop and must be suppressed | Held: evidence suppressed; conviction reversed with no retrial |
| Applicability of Sanders (window tint case) to this stop | Sanders supports that an officer’s reasonable suspicion can survive later proof of legality | Sanders is distinguishable because there the officer’s observations established a prima facie violation and the actual measurement only negated liability via an affirmative defense | Held: Sanders does not save this stop because Packard’s observations did not establish a prima facie statutory violation |
Key Cases Cited
- Curley v. State, 777 N.E.2d 58 (Ind. Ct. App. 2002) (standard of review for admissibility and suppression rulings)
- Merritt v. State, 829 N.E.2d 472 (Ind. 2005) (statutory construction principles; penal statutes construed strictly)
- Kroft v. State, 992 N.E.2d 818 (Ind. Ct. App. 2013) (statute does not require ‘only’ red light be visible)
- Sanders v. State, 989 N.E.2d 332 (Ind. 2013) (officer’s reasonable suspicion in window-tint context can be upheld despite later proof of compliance)
- Ransom v. State, 741 N.E.2d 419 (Ind. Ct. App. 2000) (officer’s mistaken belief about law does not amount to good-faith justification for a stop)