State of Delaware v. Lyric A. Carter, 2203010050

On March 18, 2022, Detective Guevara observed Lyric A. Carter driving a Toyota minivan on Memorial Drive, a high-traffic, multi-lane road.
The detective's dashcam (NVR) documented Carter drifting into the bike lane three times over a half-mile, each instance lasting several seconds.
Carter was pulled over for an alleged violation of 21 Del. C. § 4122(1), which requires drivers to stay within their lanes unless it is safe to move.
Carter was subsequently charged with driving under the influence, resisting arrest, and marijuana possession.
Carter filed a motion to suppress evidence gathered after the stop, arguing the initial traffic seizure was unconstitutional for lack of reasonable suspicion.

Issue	Carter's Argument	State's Argument	Held
Was there reasonable suspicion for stop?	There was no unsafe lane deviation; movement was safe.	Detective had reasonable suspicion due to unsafe lane entry.	Court found reasonable suspicion.
Did Carter violate 21 Del. C. § 4122(1)?	Lane deviation was for safety (avoiding headlights) and safe as no pedestrians/cyclists were present.	Proximity to parked cars made the entry unsafe.	Court found violation of § 4122(1).
Was the traffic stop constitutionally valid?	Stop was invalid due to lack of reasonable suspicion.	Stop was valid as detective witnessed a safety violation.	Traffic stop was constitutionally valid.
Should evidence after the stop be suppressed?	All evidence post-stop should be suppressed under the exclusionary rule.	Evidence should not be suppressed; stop was valid.	Motion to suppress denied.

West v. State, 143 A.3d 712 (Del. 2016) (concurring opinion discusses clear lane violation context)
Caldwell v. State, 780 A.2d 1037 (Del. 2001) (sets out totality-of-circumstances standard for reasonable suspicion)