State v. Arreola, 176 Wash. 2d 284

Officer pulled over car for muffler exhaust violation after following for ~0.5 miles; officer also suspected DUI based on report and odor of alcohol
No DUI indicators observed before stop; muffler violation cited as an actual reason for stop
Officer Valdivia testified he would have stopped for the exhaust violation regardless of DUI suspicions
Trial court found muffler violation was an actual, independent reason and that DUI inquiry was primary
Court of Appeals reversed, holding muffler reason was subordinate to DUI investigation; state appealed
Supreme Court held mixed-motive stops are constitutional if the stop is actually and independently necessary to address a traffic infraction the officer reasonably suspects

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are mixed-motive stops pretextual under Article I, §7?	Chacon: stop pretextual since DUI motive dominant	Valdivia: muffler reason independent and actual	No; mixed-motive not pretextual if independent reason exists
What constitutes an independent and conscious cause for the stop?	Stop relied on unlawful primary motive	Stop justified by independent, reasonably necessary traffic infraction	Independent cause exists; stop not pretextual when independent reason is properly identified
Role of subjective intent vs objective circumstances in pretext analysis	Ladson requires focus on officer’s true motive	Court should consider both intents and circumstances	Inquiry must balance subjective intent and objective facts; focus on legitimate, independent reason

State v. Ladson, 138 Wn.2d 343 (1999) (pretextual stops prohibited; totality of circumstances standard)
State v. Snapp, 174 Wn.2d 177 (2012) (warrantless stops and privacy protections; narrow exceptions)
State v. Day, 161 Wn.2d 889 (2007) (privacy rights and limits on disturbances; reasonableness framework apart from Fourth Amendment)
State v. Doughty, 170 Wn.2d 57 (2010) (reasonable articulable suspicion required for investigative stops)
State v. Nichols, 161 Wn.2d 1 (2007) (warrantless traffic stop constitutional with probable cause or reasonable suspicion)