State of Arizona v. Aaron Raymond Fikes
267 P.3d 1181
Ariz. Ct. App.2011Background
- Officer stopped Fikes for a non-working brake light; other brake lights worked and no other infractions were observed.
- Fikes challenged the stop as lacking reasonable suspicion to investigate alleged DUI.
- Trial court denied suppression; evidence gathered at stop was used at trial and Fikes was convicted.
- On appeal, the court addresses statutory interpretation of stop-lamp maintenance and the suppression ruling.
- Ultimately the court concludes lack of reasonable suspicion invalidates the stop and orders vacatur and remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop supported by reasonable suspicion? | Fikes contends there was no reasonable suspicion. | State argues authority to stop for a non-working stop lamp under § 28-939/B. | No reasonable suspicion; stop unconstitutional. |
| Does § 28-939(B)(1) require only one stop lamp to be maintained? | Fikes emphasizes one nonworking lamp among multiple. | State asserts ambiguity; argues maintenance requires multiple lamps. | Statute is ambiguous; only one stop lamp need be maintained. |
Key Cases Cited
- State v. Blakley, 226 Ariz. 25 (Ariz. App. 2010) (standard for reviewing suppression rulings: consider suppression evidence as presented)
- State v. Valle, 196 Ariz. 324 (Ariz. App. 2000) (accept findings unless abuse of discretion; de novo for statutory interpretation)
- State v. Gonzalez, 216 Ariz. 11 (Ariz. App. 2007) (statutory interpretation review when language is ambiguous)
- State v. Fornof, 218 Ariz. 74 (Ariz. App. 2008) (vehicle seizure requires reasonable suspicion; Fourth Amendment)
- State v. Teagle, 217 Ariz. 17 (Ariz. App. 2007) (reasonable suspicion standard for investigatory stops)
- Bilke v. State, 206 Ariz. 462 (Ariz. 2003) (interpretation of legislative purpose; maintain consistency with legislative intent)
- Obregon v. Indus. Comm’n, 217 Ariz. 612 (Ariz. App. 2008) (interpretation of maintenance provisions; emphasis on text and context)
- Egan v. Fridlund-Horne, 221 Ariz. 229 (Ariz. App. 2009) (statutory interpretation when language used variably indicates meaning)
- Sweet v. State, 143 Ariz. 266 (Ariz. 1985) (principle of in pari materia; reliance on related statutes)