State v. Beckstrom
2013 UT App 104
| Utah Ct. App. | 2013Background
- Beckstrom appealed after pleading guilty to a third-degree DUI resulting in serious bodily injury; conviction affirmed.
- Accident occurred on a snowy night when Beckstrom drove the wrong way on a four-lane street in Lehi, injuring a couple who were transported to the hospital.
- Officer observed slurred speech, glossy eyes, alcohol odor, and stumbling; she admitted drinking vodka shots.
- Officer chose to relocate Beckstrom to a heated police station testing location rather than administer tests at roadside or inside a store, citing weather and recording feasibility concerns.
- Beckstrom consented to the relocation and testing; intoxilyzer showed BAC 0.228; she was charged with DUI and a traffic offense; she pled not guilty and moved to suppress the evidence.
- Trial court denied suppression, ruling that transport to the station for testing did not exceed the scope of an investigative detention; Beckstrom entered a conditional no-contest plea to the DUI charge, preserving appeal on suppression issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Beckstrom’s extended detention for field sobriety testing permissible? | Beckstrom argues the transportation to the station exceeded investigative detention. | Beckstrom argues the detention was unlawful and the testing should have occurred where initially stopped. | Yes, permissible under totality of circumstances per Worwood. |
| Was Beckstrom’s consent to transport and testing voluntary and adequate to justify the actions taken? | Consent was coerced or not voluntary. | Consent was voluntary and not coerced, supported by findings. | Consent was voluntary; transportation did not violate Fourth Amendment limits. |
Key Cases Cited
- State v. Worwood, 164 P.3d 397 (Utah 2007) (probable cause and detention scope in DUI investigations; transport impact on detention)
- State v. Simons, 296 P.3d 721 (Utah 2013) (reasonableness of extension of detention under totality of circumstances)
- United States v. Sharpe, 470 U.S. 675 (1985) (reasonable suspicion standard for brief detention and less intrusive means)
- State v. Menke, 787 P.2d 537 (Utah Ct. App. 1990) (probable cause and movement related to DUI arrest)