People v. Dunbar
499 Mich. 60
| Mich. | 2016Background
- Early morning traffic stop after deputies followed defendant's Ford Ranger pickup and checked its plate using LEIN.
- Officer saw a towing ball partially obstructing the rear registration plate and entered an uncertain plate number into LEIN, prompting the stop.
- On approach officers smelled burnt marijuana; a search uncovered marijuana, cocaine, and a handgun.
- Defendant moved to suppress the contraband, arguing the initial stop lacked reasonable suspicion and was therefore an unlawful seizure.
- Trial court denied suppression, finding a violation of MCL 257.225(2) (obstructed plate); Court of Appeals reversed, holding the statute did not prohibit obstruction by a towing ball.
- Michigan Supreme Court granted review and reversed the Court of Appeals, holding the towing ball obstructed the plate in violation of MCL 257.225(2), so the stop was lawful.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MCL 257.225(2) prohibits a towing ball attached to a vehicle from partially obstructing a registration plate | Statute requires plate be attached in a place and position that is "clearly visible," so obstruction by a towing ball violates the statute | Statute applies to foreign materials on the plate and legibility, not to common attachments like towing balls; statute ambiguous/vague if read otherwise | The statute’s second sentence requires unobstructed placement; obstruction by a towing ball violated MCL 257.225(2) |
| Whether the traffic stop was lawful (reasonable suspicion/probable cause) | If plate obstruction violated the statute, officers had lawful basis to stop | Stop unlawful because plate itself was legible and statute doesn’t cover towing attachments | Stop was lawful because officers observed a statutory violation (obstructed plate) |
| Whether any vagueness or overbreadth claim defeats enforcement | N/A (state argued statute is clear) | Argued statute ambiguous/vague as it could criminalize common equipment | Court held statutory language clear; policy/overbreadth concerns are for Legislature |
| Whether officers could rely on a reasonable mistake of law (Heien) | N/A (alternative argument) | If statute unclear, Heien permits stop based on reasonable legal error | Court found no legal mistake because statute was violated; Heien not needed |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (traffic-stop probable-cause standard)
- Heien v. North Carolina, 574 U.S. 54 (reasonable mistake of law can justify stop)
- People v. Dunbar, 306 Mich. App. 562 (Court of Appeals decision reversing suppression)
- People v. Tanner, 496 Mich. 199 (standard of review for suppression rulings)
- Gardner v. Dep’t of Treasury, 498 Mich. 1 (statutory interpretation and enforcing unambiguous text)