State of Tennessee v. Mark Rollins, M2016-00162-CCA-R3-CD

Mark Rollins was stopped by Murfreesboro police after failing to signal a turn; officers observed signs of impairment and arrested him for DUI.
The affidavit of complaint recounted slurred speech, bloodshot eyes, unsteadiness, odor of an intoxicant, and failed field sobriety tests.
Rollins filed a motion to suppress, arguing the traffic stop was an illegal seizure because the city ordinance did not specify when signaling was required.
The trial court denied the motion, finding the officers had probable cause to stop Rollins for a traffic violation (failure to signal).
Rollins pled guilty to DUI but reserved a certified question of law challenging whether the stop was supported by reasonable suspicion or probable cause.
The Court of Criminal Appeals reviewed the denial of the suppression motion and affirmed, holding the municipal ordinance required signaling and therefore the stop was supported by probable cause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the initial traffic stop was lawful	State: Officers had probable cause to stop Rollins for violating the city no-signal ordinance	Rollins: The Murfreesboro ordinance does not specify when a driver must signal, so stop was unlawful	Court: Ordinance clearly requires a signal when turning; officers had probable cause; stop lawful

Terry v. Ohio, 392 U.S. 1 (1968) (permits brief investigatory stops on reasonable suspicion)
Delaware v. Prouse, 440 U.S. 648 (1979) (stopping a vehicle is a seizure implicating Fourth Amendment)
United States v. Sokolow, 490 U.S. 1 (1989) (reasonable-suspicion standard lower than probable cause; totality-of-circumstances test)
State v. Odom, 928 S.W.2d 18 (Tenn. 1996) (standard of review for suppression hearings)
State v. Dotson, 450 S.W.3d 1 (Tenn. 2014) (definition of probable cause for arrests)