State of Tennessee v. Michael Chris Luthi, M2016-00427-CCA-R3-CD

At ~7:00 a.m. in Tullahoma, Trooper Donnie Clark pulled up behind Michael Chris Luthi's pickup at a stop sign and observed through the rear window that Luthi was not wearing a seat belt.
The trooper stopped the vehicle for a seat-belt violation, made contact, and determined Luthi was impaired; evidence from the subsequent stop was contested as fruit of an unlawful stop.
Luthi moved to suppress evidence, arguing the rear window tinting and the police video made it impossible to see whether he was belted and that the stop therefore lacked reasonable suspicion.
At the suppression hearing the court admitted Trooper Clark's testimony and his in-car video; the judge found the trooper credible and concluded the trooper could see Luthi was unbelted when he stopped the vehicle.
A jury convicted Luthi of DUI (third offense) and seat-belt violation; Luthi appealed, challenging denial of the suppression motion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Luthi)	Held
Whether the trooper had reasonable suspicion to stop the vehicle	Trooper observed no seat-belt shadow/outline; officer's observation provided reasonable suspicion for investigatory stop	Video and window tinting show it was impossible to see whether a seat belt was worn, so no reasonable suspicion existed	Court affirmed: trooper credible; totality supported reasonable suspicion
Whether the video preponderates against trial court credibility finding	Video is consistent with trooper's in-person observations and shows head/shoulder area visible	Video image quality and tinting undermine trooper's claim and preponderate against court's finding	Court held evidence did not preponderate against trial court credibility finding

Terry v. Ohio, 392 U.S. 1 (investigatory stop exception to warrant requirement)
Whren v. United States, 517 U.S. 806 (officer's subjective intent irrelevant if objective grounds exist for stop)
Delaware v. Prouse, 440 U.S. 648 (stops must be justified by probable cause or reasonable suspicion)
State v. Brotherton, 323 S.W.3d 866 (articulable and reasonable suspicion inquiry governs legality of traffic stops)
State v. Odom, 928 S.W.2d 18 (trial court's credibility and factual findings in suppression hearings are owed deference)
State v. Binette, 33 S.W.3d 215 (warrantless searches per se unreasonable; investigatory stop standard)
Ornelas v. United States, 517 U.S. 690 (reasonable suspicion is objective and evaluated under totality of circumstances)