State v. Dahl
809 N.W.2d 844
S.D.2012Background
- Dahl was convicted of third-offense DUI in a bench trial after a stop by Aberdeen police.
- Officer Koval stopped Dahl at about 10:49 p.m. on Southeast Sixth Avenue after observing a wide right turn that allegedly crossed a lane line.
- Dahl moved to suppress all stop-derived evidence, contending the stop lacked reasonable suspicion.
- The circuit court reviewed dash-cam video and found Dahl clearly crossed the line, supporting reasonable suspicion.
- Dahl was convicted and sentenced to two years with one year suspended; on appeal, he challenged the stop as unlawful.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was supported by reasonable suspicion | Dahl argues no reasonable suspicion. | Koval reasonably believed a traffic violation occurred. | Yes; stop supported by reasonable suspicion. |
| Whether officer's mistaken belief about the law invalidates the stop | Dahl argues mistake of law invalidates the stop. | Officer's interpretation could be reasonably made under the statute. | Stop valid; not invalidated by officer's mistake of law. |
Key Cases Cited
- State v. Bergee, 753 N.W.2d 911 (2008 S.D. 67) (standard for reviewing suppression motions; reasonable-suspicion standard applied de novo)
- State v. Hayen, 751 N.W.2d 306 (2008 S.D. 41) (reasonableness of searches and seizures; totality-of-the-circumstances approach)
- State v. Herren, 792 N.W.2d 551 (2010 S.D. 101) (totality-of-the-circumstances and particularized basis for suspicion)
- United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-the-circumstances reasonable-suspicion standard)
- State v. Quartier, 753 N.W.2d 885 (2008 S.D. 62) (clarifies reasonable-suspicion standard for traffic stops)
- State v. Akuba, 686 N.W.2d 406 (2004 S.D. 94) (defines specific, articulable facts required for reasonable suspicion)
- State v. Wright, 791 N.W.2d 791 (2010 S.D. 91) (mistake of law cannot justify a stop; objective reasonableness required)
- Webb v. SD Dept. of Regulation, 680 N.W.2d 661 (2004 S.D. 63) (applies reasonableness-and-law interpretation in stops)
- State v. Ballard, 617 N.W.2d 837 (2000 S.D. 134) (crossing lines can support reasonable suspicion)