State of Tennessee v. Tonya Lavette Christopher, E2015-02038-CCA-R3-CD

At ~1:00 a.m. on Aug. 30, 2014, CPD Officer Hunter Morgan observed a car stopped near the Nautical Way / Holiday Hills Circle intersection with doors open and lights on; he testified the vehicle was stopped "in the middle of the road."
Officer pulled his patrol car behind the vehicle with blue lights and approached; he smelled alcohol, saw alcohol in the vehicle, and observed the driver (Christopher) unsteady when attempting to exit.
Officer administered field sobriety tests, which Christopher failed; her blood alcohol concentration was later 0.209%.
Defense witnesses testified the car was pulled to the side, a passenger had a door open over grass, and the car had been stopped briefly while occupants talked. A defense investigator measured the roadway width and opined another car could have passed.
Trial court credited Officer Morgan's testimony that the car obstructed the roadway (doors open, occupant outside), denied the suppression motion, and Christopher pled guilty to first-offense DUI while preserving a certified question whether the stop was supported by reasonable suspicion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Christopher)	Held
Was there a seizure?	Officer activation of blue lights and pulling behind constituted a seizure.	Agreed seizure occurred (issue focuses on justification).	Court agreed the officer’s activation of lights and positioning effected a seizure.
Was the investigatory stop supported by reasonable suspicion of a crime (obstructing a roadway under Tenn. Code Ann. § 39-17-307)?	Officer observed vehicle stopped in middle of road with doors open and a person outside; these facts, plus time and neighborhood, gave reasonable suspicion.	Evidence (witnesses, roadway width) preponderates that car was at side of road, not obstructing; even if mid-road, there was room to pass and no other traffic.	Court deferred to trial court credibility findings, concluded officer had reasonable suspicion that defendant was obstructing the roadway, so the stop was lawful.
Is Williams v. State controlling to require suppression?	State distinguished Williams because here additional facts (open door, occupant outside, uncertainty of movement) supported suspicion.	Christopher argued Williams required suppression because no active obstruction/other traffic.	Court held Williams not controlling; factual differences justified the stop.

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (investigatory stop requires reasonable, articulable suspicion)
Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (Fourth Amendment applies to states)
State v. Williams, 185 S.W.3d 311 (Tenn. 2006) (officer lacked reasonable suspicion where vehicle stopped but not obstructing traffic)
State v. Odom, 928 S.W.2d 18 (Tenn. 1996) (standard of review for suppression hearing findings)