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State v. Gerald Edward Voss
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Background

  • Officer observed Gerald Voss driving in a 35 mph zone and obtained a radar reading of 45 mph.
  • Officer stopped Voss for speeding; the stop led to Voss’s arrest for DUI.
  • Voss moved to suppress evidence from the stop, arguing he was permitted to drive 45 mph because a 45 mph speed limit sign was within his line of sight.
  • The district court denied the motion to suppress; Voss pleaded guilty to felony DUI while reserving the right to appeal the suppression ruling.
  • The court evaluated whether the officer had reasonable and articulable suspicion to initiate the traffic stop based on the radar reading and applicable law.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the traffic stop was supported by reasonable suspicion to enforce a speeding violation Voss: he was permitted to drive 45 mph because a 45 mph sign was visible State: radar showed Voss at 45 mph while still in a 35 mph zone, supplying reasonable suspicion Stop was valid; motion to suppress denied

Key Cases Cited

  • Atkinson v. State, 128 Idaho 559, 916 P.2d 1284 (discussing standard of review for suppression rulings)
  • Valdez-Molina v. State, 127 Idaho 102, 897 P.2d 993 (trial court’s credibility determinations at suppression hearings)
  • Schevers v. State, 132 Idaho 786, 979 P.2d 659 (trial court’s factual role at suppression hearings)
  • Delaware v. Prouse, 440 U.S. 648 (traffic stops implicate Fourth Amendment seizure principles)
  • United States v. Cortez, 449 U.S. 411 (reasonable, articulable suspicion standard evaluated on totality of circumstances)
  • Flowers v. State, 131 Idaho 205, 953 P.2d 645 (application of reasonable suspicion to traffic stops)
  • Ferreira v. State, 133 Idaho 474, 988 P.2d 700 (totality-of-circumstances analysis for reasonable suspicion)
  • Montague v. State, 114 Idaho 319, 756 P.2d 1083 (officer may draw reasonable inferences from training and experience)
  • McCarthy v. State, 133 Idaho 119, 982 P.2d 954 (placement of speed limit signs marks new speed zones)
Read the full case

Case Details

Case Name: State v. Gerald Edward Voss
Court Name: Idaho Court of Appeals
Date Published: Oct 26, 2016
Court Abbreviation: Idaho Ct. App.