People of Michigan v. Nathan Lee Schuch
372196
Mich. Ct. App.Mar 11, 2025Background
- Defendant Nathan Lee Schuch was charged with Operating While Intoxicated (OWI) after being involved in a single-vehicle accident near his home in Jackson County, Michigan.
- Deputy Jenski responded to Schuch's call reporting the accident and observed strong odor of alcohol, bloodshot eyes, and slurred speech; Schuch admitted to drinking earlier that day.
- Deputy Jenski administered three field sobriety tests, but performed two incorrectly and did not observe intoxication signs in the third.
- Schuch moved to suppress evidence from his arrest, contending lack of probable cause due to improperly administered sobriety tests.
- The district court denied suppression, finding probable cause; the circuit court reversed, ruling probable cause was lacking; the State appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether probable cause existed for OWI | Probable cause was present based on observations & admissions | No probable cause due to invalid tests | Probable cause existed; suppression motion denied. |
Key Cases Cited
- People v. Slaughter, 489 Mich 302 (Mich. 2011) (standard of review for suppression hearings and probable cause)
- People v. Chapo, 283 Mich App 360 (Mich. Ct. App. 2009) (defining probable cause for arrest)
- People v. Nguyen, 305 Mich App 740 (Mich. Ct. App. 2014) (probable cause does not require actual criminal activity)
- People v. Cohen, 294 Mich App 70 (Mich. Ct. App. 2011) (probable cause based on totality of circumstances)
- People v. Rizzo, 243 Mich App 151 (Mich. Ct. App. 2000) (odor of alcohol as basis for reasonable suspicion)