State v. Gerald Edward Voss
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)
