State of Tennessee v. David Dwayne Bell
2014 Tenn. LEXIS 121
| Tenn. | 2014Background
- Bell drove the wrong way on a divided highway early May 13, 2009; deputy stopped him within Sevierville city limits.
- Bell smelled of alcohol and admitted consuming more than he should.
- Officer Russell administered non-standardized tests (four-finger count, alphabet, birth year) and standardized tests (HGN not argued, walk-and-turn, one-leg stand).
- Bell completed non-standardized tests satisfactorily; some issues were noted with walk-and-turn and the one-leg stand lasted to 23 seconds.
- Bell was arrested for DUI, and charges were later suppressed by the trial court based on lack of probable cause.
- Court of Criminal Appeals affirmed the suppression; supreme court reversed, holding probable cause existed despite some favorable SFST results.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether probable cause existed for warrantless DUI arrest | Bell passed field sobriety tests, undermining probable cause | Bell’s totality of circumstances still supported probable cause | Probable cause existed; arrest valid |
| Weight of field sobriety test results in probable-cause analysis | SFST results negate probable cause | SFST are only one factor in totality of circumstances | SFST weight is one factor among totality; does not defeat probable cause |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (probable-cause standard is a practical, nontechnical inquiry)
- Beck v. Ohio, 379 U.S. 89 (U.S. 1964) (probable cause requires reasonable grounds for belief of guilt)
- State v. Echols, 382 S.W.3d 266 (Tenn. 2012) (probable cause as a mixed question of law and fact)
- State v. Day, 263 S.W.3d 891 (Tenn. 2008) (probable-cause framework; suppression standard)
- State v. Grier, 791 P.2d 627 (Alaska Ct. App. 1990) (probable cause despite some nondiagnostic test results)